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Disclosures Employees of M. M. Dillon & Co. are Associated Persons (as that term is defined under the Securities Exchange Act of 1934, as amended, and the rules administered by the Financial Industry Regulatory Authority, Inc.) of M.M. Dillon & Co. LLC.
M.M. Dillon & Co. LLC and any associated person employed by it, will at all times during an engagement, be properly registered as a broker-dealer pursuant to Section 15(b) of the Securities Exchange Act of 1934, and under the laws of each applicable state, and in good standing with the Financial Industry Regulatory Authority, Inc.
Business Continuity Plan (BCP) M.M. Dillon & Co. LLC maintains a Business Continuity Plan (BCP) consistent with regulatory requirements. We are providing this disclosure statement, which summarizes the BCP, to our clients. The BCP is reviewed annually and may be updated at any time.
M.M. Dillon & Co. LLC is an introducing firm and does not perform its own or others� clearing functions. We do not hold customer�s securities or funds. Sterne Agee Clearing, a Division of Sterne Agee, compares, allocates, clears and settles all M.M. Dillon & Co. LLC transactions. Our clearing firm maintains our customer�s accounts, and in the event of a Significant Business Disruption can grant customers access to them to deliver securities and funds.
Our clearing firm, Sterne Agee Clearing, maintains a business continuity plan and the capacity to execute that plan: http://www.sterneagee.com Sterne Agee asserts that it will advise us of any material changes to its plan that might affect our ability to maintain our business and has presented us with an executive summary of its plan. In the event that Sterne Agee executes its plan they will notify us of such execution. Sterne Agee affirms that it backs up our records at a remote site and that it operates a back-up operating facility in a geographically separate area with the capability to conduct the same volume of business as its primary site. Sterne Agee has also confirmed the effectiveness of its back-up arrangement to recover from a wide scale disruption by testing, and it has verified that it tests its back-up arrangements.
Our BCP will be activated in the event of a Significant Business Disruption (SBD). The BCP attempts to continue operations if an event were to occur that would impact the firm�s business locations or systems. We have analyzed a variety of significant business disruptions and the actions M.M. Dillon & Co. LLC would take in the event of a building, town-wide or regional incident. The BCP states that after performing an initial assessment of the event, the CEO or CFO would execute our BCP.
Under most scenarios, we expect to continue to do business and resume operations with minimal service impact. However, under certain circumstances, the time it takes to recover and resume operations may be significantly increased depending on the extent of the disruption to our systems and physical structures.
Clients may be kept up to date on the potential business disruption scenarios by accessing
http://www.mmdillon.com. They may also call our main office number at 203-569-6800 to get information about accessing their securities and funds at our clearing firm.
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