Business Continuity Planning

Nancy Barron & Associates (NBA) has developed a Business Continuity Plan on how we will respond to events (ice storms, fire, terrorism, etc.) 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 859-254-4010 toll free, you should first go to our web site at www.nancybarron.com and check for any current postings that would be found on the home page. If you cannot access us through any of those means, you should contact our clearing firm, National Financial Services, LLC (NFS), at 800-801-9942 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 you. However, please note that if we are still in operation, calls to this line will be automatically directed to us at NBA.

 

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.

Fee Schedule of Possible Charges

Form CRS with Exhibit of Changes

NBA Reg BI Disclosures

Privacy Policy

Effective January 2, 2002 in order to comply with the Privacy Provisions of the Gramm-Leach-Bailey Act, Nancy Barron & Associates, Inc. [hereinafter, “NBA”] has implemented the following NBA Privacy Policy to codify the protection of certain non-public information about their clients. This policy is intended to work in tandem with the privacy policy issued by NFSL.

 

The NBA Commitment
NBA is pledged to safeguard the use of client’s personal information that is collected in the course of doing business with those clients.

NBA does not sell any non-public information to anyone. Nor does NBA provide such information to any others except as may be necessary for discrete and proper business purposes or as mandated by authorized regulatory bodies.

 

NBA Information Collection
NBA may collect information from their clients from numerous sources, including but not limited to the following:

· Information clients may provide in establishing a new account with NBA including but not limited to their name, address, telephone number and social security numbers.

· Information clients may provide to NBA about their transactions outside NBA

· Information from consumer reporting agencies, public records and other data collection agencies.

 

NBA Information Use and Disclosure
NBA shall protect the security and confidentiality of all personal information and will make every effort to insure that such information is used solely for proper business proposes in connection with the management and servicing of the client’s account(s).

 

In situations where client information is shared [such as with correspondent clearing firms and mutual funds], NBA requires other parties to treat and maintain the privacy of that information to at least the same extent and with the same degree of diligence and careful attention that is required by NBA.

 

NBA does not disclose, and has no intention to disclose, any non-public personal information to non-affiliated third parties with respect to persons who are no longer our clients.

 

NBA Security Procedures
All NBA employees are advised about the NBA commitment to safeguard the confidentiality of our client’s non-public personal information. In addition, NBA maintains physical, procedural and electronic safeguards to protect this information from unauthorized access and dissemination.

 

Client Rights
NBA will send all clients a notice of our privacy policy annually for as long as a client maintains an ongoing business relationship with NBA. The practices and policies contained in this disclosure are subject to change, but NBA will communicate any material changes to their clients and provide a revised notice incorporating any material changes before NBA implements such changes.

SEC Rule 606 Quarterly Report