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Aspetuck Financial Management LLC (the “Firm”) is providing you with this document to inform you of its ability to respond to certain business disruptions at Aspetuck Financial Management LLC. Aspetuck Financial Management LLC, is associated with TD Ameritrade Institutional Services (TD) and Charles Schwab Institutional Services (Schwab). Ability to respond to business disruptions is  important to your relationship with Aspetuck Financial Management LLC. TD and Schwab are our custodians. Our Custodians hold your assets and along with their respective Broker/Dealer, they process all transactions in your brokerage account as directed by the Firm and owner of account. In general, Aspetuck Financial Management LLC, TD, and Schwab maintain business continuity plans and intend to continue business in the event of a significant business disruption.

 Aspetuck Financial Management LLC has made arrangements and plans to service your business in case our offices are closed for either one day or an extended period of time. Certain services such as the execution of securities transactions and the maintenance of customer funds and securities are expected to be available even if the offices are closed due to a business disruption event.  Accordingly, the Firm’s ability to respond to certain business disruptions is partially dependent on TD Ameritrade Inc. and or Charles Schwab & Co. Inc. to carry out those functions.

 In the event of a significant business disruption, the firm may route calls to our custodians from alternate locations, or transfer operations to the alternate emergency office (1400 Cross Highway Fairfield CT; Tele # 203-216-4882).  Although Aspetuck Financial Management LLC intends to continue business in the event of a significant business disruption, there are some disruptions that may render the Firm unable to continue business.  Under such circumstances, the Firm will ensure that clients will be able to access their funds and securities within a reasonable time.

To provide clients with up-to-date information during a significant business disruption to Aspetuck Financial Management LLC office, clients may call the Firm’s telephone number at (203) 226-5733 or visit our Business Continuity Information Web page at www.aspetuckfinancial.com. If for any reason the main line is not in service, then clients should use the following emergency number, 203-216-4882. 

 I.  Aspetuck Financial Management LLC Response to Events of Varying Scope:

 The following sections describe specific events and Aspetuck Financial Management LLC corresponding general response to those events.  Clients, however, should note that these responses are subject to modification and, depending on the severity of a specific event; Aspetuck Financial Management LLC cannot guarantee that it will be able to follow the stated course of action.  If these responses are modified, Aspetuck Financial Management LLC will update the information on its Web site.  

 If Aspetuck Financial Management LLC office is closed for more than one to five days, we plan to service your business from alternate locations by telephone and using web based technology provided by our broker/custodian. You will be instructed via our website or by recorded message on how to contact your Investment Adviser in order to conduct business. All business related documents can be mailed by overnight courier to the address stated on our recorded message and on our web site. Alternate emergency address to use if our office is closed down is 1400 Cross Highway, Fairfield, CT. 

 If Aspetuck Financial Management LLC office is closed for more than five to ten business days, we plan to service your business from a pre-arranged alternate location. Clients will be able to visit our temporary office. You will be instructed via our website or by recorded message on how to contact your Investment Adviser in order to conduct business and get the address of our alternate temporary office.

If Aspetuck Financial Management LLC office is closed for more than ten business days, we plan to service your business from an alternative location based in theWestport area indefinitely until further notice. You will be instructed via our website or by recorded message on how to contact your Investment Adviser in order to conduct business and get the address of our alternate office.

Under the following scenarios, Aspetuck Financial Management LLC intends to continue its business:

A Disruption to a single building or Firm-Only business disruption

These disruptions may be caused by physical damage, technology problems, or an inability to have personnel arrive at an office.  In the event that there is a significant business disruption to a single building or the Firm’s internal primary systems, Aspetuck Financial Management LLC may, if necessary, transfer its operations or route incoming calls to TD Ameritrade Advisory Services and Charles Schwab Institutional Services, another alternative office in Westport area, or provide instructions via our website and telephone message on how to conduct business.  From this separate location, Aspetuck Financial Management LLC. will accept client orders.   In this process, clients may experience a minor delay in reaching the firm due to increased client calls, technology delays, or other minor difficulties arising from the transfer of operations.  Aspetuck Financial Management LLC expects that operations could be disrupted for several hours or days.  If TD Ameritrade Advisory Services and or Charles Schwab Institutional Services Inc. trading platform is affected, there may be a more significant delay.  TD Ameritrade Advisory Services and Charles Schwab Institutional Services Ameritrade Inc., however, will be able to place orders outside the trading platform.

A Business-District, City-Wide or Regional Disruption

In the event that there is a significant business disruption that affects the business district, city or region where any of the Aspetuck Financial Management LLC primary systems are located, Aspetuck Financial Management LLC may, if necessary, transfer its operations or route incoming calls to an alternate temporary office.  In this process, Aspetuck Financial Management LLC may experience a minor delay in reaching our Custodians due to increased client calls, technology delays or other minor difficulties arising from the transfer of operations.

II. In the event that Aspetuck Financial Management LLC employees cannot be accessed by clients.

If clients cannot make contact with a Aspetuck Financial Management LLC appropriate service personnel, then clients with a TD account must call TD at 1-866-268-3247 or if client has a Schwab account, call (877) 347-6984, for assistance. If our custodians are also experiencing an emergency, then visit TD Ameritrade or Schwab’s emergency web page for instructions:

TD Ameritrade accounts login at www.ameritradeadvisor.com,

Charles Schwab accounts login at www.schwaballiance.com

Send all deposit and account related documents to:

TD Ameritrade Accounts:

For standard Delivery:
TD Ameritrade Institutional Services, 4075 Sorrento Valley Blvd., Suite A, San Diego, CA  92121  For Overnight:
TD Ameritrade Institutional Services, 1005 North Ameritrade Place, Bellevue, NE 68005

Charles Schwab Accounts:

For standard Delivery:

Charles Schwab & Co. Inc./Schwab Institutional
PO Box 628290
Orlando FL 32862-9906

 For Overnight:

Charles Schwab & co. Inc.
Attn: National Service Team
3133 East Camelback
Phoenix, AZ 85016

 A.         Trades
Custodians will process the following closing security trades:  (1) Sale of security position held long in your account or (2) Purchase of a security to close-out a short security position.  These orders will only be handled as market orders. In order to place these specific orders, you must provide our Custodians with the following information:

Your brokerage account number;

1.     Your name (as registered on the brokerage account);

2.     Security description, including symbol or CUSIP® number; and

3.     Number of shares

B.         Cash Disbursements

Our Custodians will process cash disbursements upon written instructions that must include the following information:

1.     Your brokerage account number;

2.     Your name (as registered on the brokerage account);

3.     Exact amount to be disbursed;

4.     Indicate method of disbursement (as follows) and provide the information indicated:

a.     For a check, which is payable to account name only, indicate name and address of record check is to be mailed to;

b.    For federal funds, please indicate receiving bank name, ABA number, and receiving bank account number.  Please note that the receiving bank account name and brokerage account name must be identical unless we have a letter of authorization on file indicating alternate instructions.

C.         Securities Transfers
Our Custodians will process security transfer requests upon written instructions that must include the following information:

1.     Your brokerage account number;

2.     Your name (as registered on the brokerage account);

3.     Description of security (ies) to be transferred, including symbol(s) or CUSIP number(s);

4.     Quantity to be transferred; and

5.     Receiving account information for securities, as follows:

a.     In order to transfer your account, to another brokerage account at Pershing, please provide receiving account number at Pershing (name and address on both accounts must be the same);

b.    In order to transfer your account to another financial organization, please also provide the following information:

                      i.    Name of the receiving financial organization;
                      ii.    DTC number (if the receiving financial organization is a registered broker-dealer);
                      iii.    Account number at the receiving financial organization.