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The Cutter and Company, Inc.
Business Continuity Disclosure Policy

Currently you maintain an account at our firm, Cutter and Company, Inc.  Through your financial advisor, our firm provides technology, product, and support services for the account you maintain with us.  Your assets are held at our clearing firm, First Clearing, LLC, or directly by the mutual fund or annuity company.

Securities Industry regulations require that each member firm create and maintain a “Business Continuity Plan” (BCP), which is reasonably designed to meet our obligations to our clients in the event of a disruption to our business.  Accordingly, Cutter and Company has designed a BCP to address a variety of possible scenarios in an effort to minimize any service impact to our clients.

Some of the key areas that are addressed in our BCP include, but are not limited to the following:

  • Data back-up and recovery
  • Operation of mission critical systems
  • Financial and operational assessments
  • Alternate means of communication between our financial advisors and our clients
  • Alternate physical locations
  • Regulatory reporting
  • Communication with regulators
  • How Cutter and Company will ensure customers will have access to their account information and/or funds or securities in the event that Cutter determines it is unable to continue its business.

There are a significant variety of events that may cause business disruptions.  These events may vary in nature and scope.  Cutter and Company has anticipated the following scenarios:

  • A temporary disruption at its main offices in Chesterfield, Missouri (less than 24 hours)
  • A more lengthy disruption at its main offices in Chesterfield, Missouri
  • A city wide catastrophe
  • A regional catastrophe

In the event of a temporary or lengthy building disruption at the main office of Cutter and Company, all phones will be forwarded to our Clearing Firm utilizing an 800# number or routed to an alternate location, with a local number.  Once the disruption is over, all office phones will be switched back to our normal main line phone number.   Additionally, our web site will be updated to include emergency contact information for at least two of the principals of Cutter and Company, indicating both their home and cell phone numbers.  In the unlikely event of a city wide or regional disruption, Cutter and Company has established a relationship with another local Broker Dealer, approximately 20 miles from our location, where key employees may be relocated until the disruption has ended.  Alternatively, our key employees may be relocated to one of our financial advisor’s offices in O’Fallon, Missouri, depending on the nature and location of the emergency.  However, if the geographic incident should encompass our alternate locations, than all contact will be directed to our Clearing Firm, whose main office is located in Richmond, VA.  First Clearing LLC also has corporate offices in North Carolina and New York, offering additional contact facilities in the event of a disaster.

At a minimum the Cutter and Company BCP is reviewed, updated, and tested on an annual basis.  Additionally, our primary mission critical systems and applications are tested periodically each year to verify that all are in working order.  Our BCP is available on our website at www.cutterco.com and may be modified in the future.  If changes are made, the updated plan will be posted to the website promptly.

Our financial advisors and our clients are extremely important to us, and we believe that our BCP is designed in such a way that it will allow us to continue to provide the quality of services you have come to expect in the event of any type of disruption or emergency.  Feel free to call 636-537-8770 if you would like us to mail you a written copy of the Cutter and Company BCP plan.

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