Business Continuity Plan

Certain events may occur which impact the way our company does business, making business continuity planning essential for both you and us. When such an event has an effect that could potentially cause delays or influence our normal course of business we refer to it as a “significant business disruption” (“SBD”). Our goal as an online stock broker is to assure our continuing operation and ability to provide our customers with complete and uninterrupted access to their funds and securities. We will immediately assess each SBD and execute an appropriate plan designed to minimize the effect on our customers. Obviously such events are unpredictable, however, we have thoroughly reviewed every aspect of our current business including our physical and virtual locations, hardware, software, reliance on utilities, telephone, and internet service providers, as well as additional services provided for our web site design, development, and maintenance and other trading platforms available to our customers.

Contacting Us —If after a SBD you cannot contact us as you usually do at  info@grandwood.io, you should call our alternative number 718-961-6600 or go to our website at www.grandwood.io . If you cannot access us through either of those means, you should contact our clearing firm, Apex Clearing Corporation (“Apex Clearing”) at helpdesk@apexclearing.com, and you can go to www.apexclearing.com for instructions on how to obtain prompt access to funds and securities, enter orders and process other trade- related, cash, and security transfer transactions.

Our Business Continuity Plan — We plan to quickly recover and resume business operations after a SBD 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 SBD.

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. As an on-line broker-dealer, our technology systems are securely located at alternative data centers that are geographically separated and in different time zones. This infrastructure design ensures that if one of our data centers suffers a disruption in service, systems at an alternate region can be used to continue to provide service.

Our clearing firm, Apex Clearing, 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 the shortest time period possible. Your orders and requests for funds and securities could be delayed during this period.

As a fully disclosed firm we rely on Apex Clearing to perform many of the services involved in your securities transactions. Your funds and securities are held by Apex Clearing and not by us. As such, Apex Clearing has its own Business Continuity Plan, a copy of which is located in Firstrade’s Disclosure Center. You can also find helpful information about Apex Clearing’s Emergency Policies at https://www.apexclearing.com/emergency/.

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 or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business as quickly as possible. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business as quickly as possible. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website www.grandwood.io on how to contact us. 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.

For more information — If you have questions about our business continuity planning, you can contact us at info@grandwood.io.

Need Help? U.S. Toll Free 1.800.869.8800 Outside the US 1.718.961.6600

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Online trading has inherent risk due to system response and access times that may vary due to market conditions, system performance, and other factors. An investor should understand these and additional risks before trading. Carefully consider the investment objectives, risks, charges and expenses before investing. All investments involve risk and losses may exceed the principal invested. Past performance of a security, industry, sector, market, or financial product does not guarantee future results or returns. Grandwood is a discount broker that provides self-directed investors with brokerage services, and does not make recommendations or offer investment, financial, legal or tax advice.

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