Disclosure Statement

The Garbacz Group, Inc. has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (314) 991-1303, you should call our alternative number (314)997-0562. If you cannot access us, you should contact our clearing firm, Pershing, LLC, by mail or fax. For instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions for our clients.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, Pershing, LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 4 hours of their business disruption. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm, a building housing our firm, or even our local business district we will transfer our operations to a local site when needed and expect to recover and resume business within 4-6 hours. In a disruption affecting our business district, city, or region, we plan to transfer operations to our clearing firm if necessary, and notify you through our customer emergency number, 314 991-1303 or 314-997-0562 . If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities using the instructions below.

Customers’ Access to Funds and Securities – Our firm does not maintain custody of customers’ funds or securities, which are maintained at Pershing, LLC. In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our clearing firm on their behalf via fax or mail.

Our clearing firm is Pershing LLC,P.O. Box 2065, Plaza, Jersey City, NJ 07303-2065, fax # 201-413-5368.
Pershing Business Continuity Disclosure – May 2015

DISCLOSURE REQUIRED BY FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 4370

To address interruptions to our normal course of business, Pershing maintains a business continuity plan, which includes geographically dispersed data centers and processing facilities. The plan is reviewed annually and updated as necessary. The plan outlines the actions Pershing will take in the event of a building, city, or regional incident, including:
♣ Continuous processing support by personnel located in unaffected facilities
♣ Relocating technology or operational personnel to alternate regional facilities
♣ Switching technology data processing to an alternate regional data center

All Pershing operational facilities are equipped for resumption of business and are tested. Regarding all circumstances within our control, Pershing’s recovery time objective (RTO) for business resumption, including those involving a relocation of personnel or technology, is four (4) hours or less, depending upon the availability of external resources.

CLIENT SUPPORT

In the event that your financial organization experiences a significant business interruption, Pershing will process limited trade-related transactions, cash disbursements, and security transfers on your behalf.

Trades

Pershing will process the following closing security transactions:
• Sale of security position held long in the client’s account
• Buy of security to close-out short security position, Pershing will process closing security transactions upon receipt of written instructions that must include the following information:
• Client brokerage account number
• Client name (as registered on the brokerage account)
• Security description, including symbol or CUSIP® number
• Number of shares

Note: All orders will be handled as market orders Instructions to Pershing must be in writing and transmitted via facsimile or postal service as follows:
Pershing LLC
P.O. Box 2065
Jersey City, New Jersey 07303-2065
Fax number (201) 413-5368

Please note that this fax number is for business interruption-related issues only, and should not be used for any other purposes, such as change of address notices, account transfers, and credit verification. Information received on this fax that is unrelated to business interruption issues will not be acted upon.

Cash Disbursements

Pershing will process cash disbursements upon receipt of signed written instructions that must include the following information:
• Client brokerage account number
• Client name (as registered on the brokerage account)
• Exact amount to be disbursed
• Indicate method of disbursement (as follows) and provide the information indicated:
o Check
♣ Indicate name and address of record check is to be mailed to
o Federal Funds
♣ Indicate receiving bank name, ABA number, and receiving bank account number

NOTE: The receiving bank account name and brokerage account name must be identical unless we have a letter of authorization on file indicating alternate instructions.
Instructions to Pershing must be in writing and transmitted via facsimile or postal service as follows:
Pershing LLC
P.O. Box 2065
Jersey City, New Jersey 07303-2065
Fax number (201) 413-5368

Please note that this fax number is for business interruption-related issues only, and should not be used for any other purposes, such as change of address notices, account transfers, and credit verification. Information received on this fax that is unrelated to business interruption issues will not be acted upon.

Securities Transfers

Pershing will process security transfer requests upon written instructions that must include the following information:
• Client brokerage account number
• Client name (as registered on the brokerage account)
• Description of security(ies) to be transferred, including symbol(s) or CUSIP number(s)
• Quantity to be transferred
• Receiving account information for securities, as follows:
o Transfer to another brokerage account at Pershing
♣ Provide receiving account number at Pershing (name and address on both accounts must be the same)
o Transfer to another financial organization
♣ Name of the receiving financial organization
♣ DTC number (if the receiving financial organization is a registered broker-dealer)
♣ Name of the receiving financial organization

Instructions to Pershing must be in writing and transmitted via facsimile or postal service as follows:
Pershing LLC
P.O. Box 2065
Jersey City, New Jersey 07303-2065
Fax number (201) 413-5368

Please note that this fax number is for business interruption-related issues only, and should not be used for any other purposes, such as change of address notices, account transfers, and credit verification. Information received on this fax that is unrelated to business interruption issues will not be acted upon.

Office Location – Our Office is located at 655 Craig Road, Suite 104, Saint Louis, Mo. 63141, 314-991-1303. We engage in order taking and entry at this location.

Alternative Physical Location of Firm – In the event of an SBD, and we can no longer conduct business at our main office, we will move our operations to 12832 Topping Meadows, Saint Louis, Mo. 63131. Phone: (314) 997-0562.

Our firm maintains its primary hard copy books and records and it electronic records at 655 Craig Road. Joseph Garbacz, is responsible for the maintenance of these books and records. Hard copy records include bank records, financial reports, client documents and correspondence.

Our firm maintains its back-up hard copy and electronic copy books and records at 12832 Topping Meadows, Saint Louis, MO 63131.

In the event of an internal or external SBD that causes the loss of our paper or electronic records, we will physically recover them from our back-up site. For the loss of records stored on the server, we will use the back-up to restore data and continue operations from our alternate location site.

For more information – If you have questions about our business continuity planning, you can contact us at [email protected] or (314) 991-1303