Business Continuity Plan Summary

Barrington Research Associates, Inc., (“Barrington”) is committed to safeguarding the interests of our customers, the safety of our employees and the protection of firm property in the event of an emergency or significant business disruption (“SBD”). To this end, Barrington has established a Business Continuity Plan (“BCP”) outlining procedures and back-up systems aimed at mitigating the risks inherent with unforeseen business interruptions and to quickly recover and resume operations.

The BCP is intended to comply with the rules promulgated by the Securities Exchange Commission and National Association of Securities Dealers and covers areas such as: back-up and recovery of customer and business records; identification and backup of all mission-critical systems; financial and operational risk assessments; alternate communication between Barrington its clients, employees and regulators; alternate physical locations; assessment of critical business constituent, bank and counter-party impacts; regulatory reporting; and client access to their funds and securities. Barrington’s BCP is tested regularly and reviewed annually.

There is a broad range of scenarios under which a SBD might occur. They can be generally categorized as internal or external. Internal SBD’s include those business disruptions that affect only our firm’s ability to communicate and do business, such as a fire or power failure in our building. External SBD’s affect the operation of the securities markets or a number of firms, such as a terrorist attack, city flood, or a wide-scale, regional disruption.

Barrington conducts all of its business at its primary facility located at 161 N. Clark St., Chicago, Illinois. Protecting the infrastructure of our primary facility is a high priority because it will allow the firm to continue operations in the event of many disaster situations by permitting our employees to have access to and use of our facilities during that situation. Our primary facility is equipped with physical security measures, fire suppression systems and battery back-ups. Critical computers systems are backed up on a regular basis.

Should we encounter an internal SBD that prevents the use of our primary business facility, our goal is to relocate key personnel and forward telecommunications to our alternate site and resume business activities within 24 hours. The alternative facility is a “hot site.” In other words, the site is fully operational at all times. It is equipped with workstations that have redundant computer network connectivity, telephones, printers, fax machines, market data feeds and all other specialty equipment necessary for trading and operations. The backup trading positions are periodically checked to ensure that they are equipped with updated software and trading applications. The functionality of the backup facility is routinely tested by sales, trading and operations personnel.

Should a larger scale external SBD occur, it is our goal to resume business activities as soon as practical given the specific circumstances surrounding the SBD. Such an SBD may or may not require a relocation of operations to the alternate site. In any case, our goal remains to continue our business and protect the assets of our customers to the best of our abilities.

During any SBD, communication with employees, customers and other key business parties is of vital importance. We use a combination of general broadcast and direct-contact methods. General information such as office closures, operating hours and alternative contact information will be posted on the firm’s website. Barrington has developed an emergency contact list providing multiple points of contact for each department manager, as well as formal protocols to assist in avoiding confusion and to effectively resume business. Should you not be able to contact your salesperson, please call (800) 233-6205.

In its business, Barrington relies on a number of critical third-party providers. These providers have business continuity plans, including systems redundancies and backup locations. The most significant third-party provider is our clearing firm J.P. Morgan Clearing Corp. (“JPMCC”). Barrington relies on JPMCC to maintain customer account records, execute transactions, custody client assets and provide certain operating systems. In the case of SBD where customers are not able to contact Barrington, you should contact our clearing firm, JPMCC at 212-552-1919 for liquidating orders, check and wire requests and ACAT transfers.

In conclusion, Barrington's BCP addresses the steps the firms will take to address a temporary business disruption in a systematic and organized fashion. Of course, the effects of a disaster are difficult to predict and the disruption of systems and processes on an industry wide basis will pose great challenges to any business continuity plan. There can be no assurance that any plan can address such unforeseen contingencies. The BCP and this summary may be changed without notice. In the event of a modification, an updated summary will be posted to our website. Alternatively, customers may obtain an updated summary by requesting a written copy by mail.