Business Continuity Plan 2017

FINRA Rule 4370 requires all FINRA broker/dealers to create and maintain a Business Continuity Plan (“BCP”) and requires that emergency contact information regarding the BCP be provided to FINRA through FINRA Contact System (“FCS”) at www.finra.org/fcs.

TFS Securities, 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.

The designated principal responsible for ensuring that all requirements under Rules 4370 are adhered to and will retain all related books and records, including those indicating the required reviews, along with any amendments made at any time.

FINRA Notice to Members 04-37 outlines how our obligations under Rule 4370 previously NASD Rules 3510 and 3520, may be satisfied by participating in a corporate-wide BCP, as long as the plan addresses our specific situation, even if the affiliate or parent is not an FINRA member firm. Should we rely on such a situation, our CCO is responsible for reviewing the company-wide plan to ensure that it meets all the requirements of Rule 4370. In such a situation, we remain responsible for appropriate designation of a principal to act in the manner as described above.

We are required to designate a member of senior management, who is a registered principal, as the individual responsible for (a) approving our Business Continuity Plan (“BCP”) and (b) conducting the required annual review of our BCP, including any proposed changes to the existing BCP.

The individual designated is: Name and CRD #: Tammy S. Case and CRD#2862957 Title: Chief Compliance Officer

Senior Management BCP Approval: FINRA has made it clear that “senior management approval” is intended only to ensure that a specific individual with proper authority review and update the plan, not to make one person responsible for our compliance with Rule 4370. Compliance with Rule 4370 is deemed to be a firm-wide compliance matter.

The designated principal will ensure that emergency contact information is given (and continually updated as required) to FINRA (through the FCS). This information requires us to designate two (2) emergency contact persons FINRA may contact in the event of a significant business disruption. Each emergency contact person must be a registered principal and a member of senior management. FINRA Notice to Members 04-37 outlines alternative measures, such as utilizing outside counsel, for instances where a firm has only one principal or is a sole proprietorship.

The two emergency contact persons so named are:

(1) Name / CRD #: Thomas P. Hyland and CRD# 1523873 Title: President

(2) Name / CRD #: Tammy S. Case and CRD# 2862957 Title: CCO

In the event of a material change, our CCO is responsible for ensuring that we promptly update our emergency contact information (“Emergency Contact Information Review and Updating”). These names will be updated in the event of a material change, and our Executive Representative will review them within 17 business days of the end of each quarter.

In addition, an appropriate designated individual will review, minimally on an annual basis, the FCS system to ensure the information remains current. Any changes must be made within 30 days of different individuals being designated as an emergency contact person.

Our CCO will ensure that we maintain copies of our BCP plan, annual reviews, and changes that have been made to it for regulatory inspection purposes.

To ensure accessibility of regulators upon request, an electronic copy of our plan is located on the J Drive of our network in the J:|BCP folder.

Recognizing that not all firms have a secure, off-site facility to store and update their BCP, FINRA has arranged for EVault, a leading provider of network backup and recovery software and services, to provide this voluntary electronic repository service specifically designed for FINRA firms.

Use of the BCP Repository Service is entirely voluntary and is not required by FINRA rules. Furthermore, use of the BCP Repository Service does not constitute a "safe harbor" with respect to a member firm's obligation to comply with all applicable rules and regulations. Currently TFS Securities, Inc. does not use the services of EVault.

Our CCO will make a determination, working with Senior Management, as to whether or not we choose to utilize EVault’s services in the future, and to ensure full compliance should the determination be made to use FINRA’s backup and recovery system for our BCP.

Our CCO is responsible for ensuring that we update our BCP in the event of any material changes to our operations, structure, business or location(s). This updating must be accomplished in a timely manner.

In addition, our CCO will ensure that if an individual other than the CCO has been designated as having the BCP annual review responsibility does, in fact, undertake such a review to determine if any updates are needed in light of any changes to our operations, structure, business or location(s).

In reviewing our BCP, we must ensure that it addresses our anticipating two kinds of significant business disruptions (“SBDs”), internal and external.

Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building.

External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption.

Our response to an external SBD relies more heavily on other organizations and systems (i.e. a clearing firm, an issuer, bank, etc.).

At a minimum, our BCP must address the ten (10) key areas listed below; to the extent they are applicable and necessary. We should also identify and address other key areas which may be required to be included to ensure our BCP is complete and thorough, based on our specific business and operations.

For any of the ten (10) key areas listed below determined (based on our specific business model) not to be required in our BCP, the BCP must include a rationale for it not being addressed. It is not sufficient merely to omit a specific required category.

For any area where we are relying upon the BCP of another entity, we must have access to that entity’s BCP, or request that they prepare an Executive Summary of their BCP as to its relevance for our use in complying with Rule 4370. This Executive Summary would be required to be an integral portion of our BCP.

1. Data Back-Up and Recovery (Hard-Copy and Electronic) 2. Mission Critical Systems (defined in FINRA Notice to

Members 04-37 as “any system that is necessary, depending upon the nature of a broker/dealer’s business, to ensure prompt and accurate processing of securities transactions, including but not limited to order taking, order entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer account and the delivery of funds and securities.”)

3. Financial and Operational Assessments (written procedures to ensure our ability to identify changes in our operational, financial and credit risk exposures)

4. Critical Business Constituent, Bank and Counter-Party Impact

5. Prompt Access by Customers to their Funds and Securities

6. Alternative physical location of employees 7. Alternate Communications Between the Firm and

Customers 8. Alternate Communications Between the Firm and its

Employees 9. Alternate Communications Between the Firm and the

Regulators 10. Regulatory Reporting

“Operational risk” focuses on a firm’s ability to maintain communications with customers and to retrieve key activity records through our mission critical systems. “Financial (and credit) risk” relates to a firm’s ability to continue to generate revenue and to retain or obtain adequate financing and sufficient equity.

In addition, our BCP must also take include:

A detailed description of our business

A listing of all business locations

Dissemination of the Plan and Each Individual’s Responsibilities There under

Under Rule 4370 we are required to disclose certain portions of our BCP to customers. Such disclosure statement, with description as to its distribution methods, is required to be an integral part of our BCP.

Our BCP must address how we will ensure that such disclosure is made at the time a new account is being opened and at other times if applicable (i.e. annually). We must also indicate that we will mail a copy of our BCP disclosure to customers upon request and we may also put the Summary Disclosure on our web site.

Our BCP Summary must address the possibility of a future SBD and how we plan to respond to events of varying scope. In addressing the events of varying scope, our Summary must:

1. provide specific scenarios of varying severity (e.g., a firm-only business disruption, a disruption to a single building, a disruption to a business district, a city-wide business disruption, and a regional disruption);

2. state whether we plan to continue business during that scenario and, if so, our planned recovery time;

3. provide general information on our intended response; and 4. disclose the existence of back-up facilities and arrangements.

We need not disclose the following factors:

the specific location of any back-up facilities; any proprietary information contained in the plan; or the parties with whom we have back-up arrangements.

The Summary may also include cautionary language indicating that the plan is subject to modification, that an updated summary will be promptly posted on our web site (if applicable), and that customers may alternatively obtain updated summaries by requesting a written copy by mail.

Copies of our initial BCP and any changes will be maintained, evidencing appropriate senior management approval by initials and dates.

Documentation concerning maintenance of current information (required on an annual basis, with any changes required to be made within 30 days of any change) on FINRA's FCS regarding emergency contact individuals will be retained, evidenced by copies of the filings or by initialing appropriate changes made, indicating who made the changes (or verified that the information was to remain unchanged), as well as when such changes or verifications were made.

Documentation as to the required Annual Review of our BCP will be maintained, indicating who conducted the review, the dates of all review activities, comments

relating to required changes, and indications that changes were made (including evidence of who made the changes and to whom the revised BCP was distributed).

Evidence of our BCP disclosure customers is retained in the filings, indicating how disclosure was made, when it was made and by whom.

UUFIRM POLICY Our firm’s policy is to respond to a significant business disruption by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure our customers of prompt access to their funds and securities.

1. Significant Business Disruptions (SBDs)

Our Plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or affect a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm, Pershing LLC.

2. Approval and Execution Authority

Tammy S. Case, CCO, a registered principal, is responsible for approving the plan and for conducting the required annual review. Thomas P. Hyland, President, has the authority to execute this BCP.

3. Plan Location and Access

Our firm will maintain copies of its BCP and any changes that have been made to it for inspection. An electronic copy of our plan is located on the “J” Drive of our network in the J:\BCP folder.

UUBUSINESS DESCRIPTION Our firm conducts business as an introducing firm and does not perform any type of clearing function for itself or for others. Furthermore, we do not hold customer funds or securities. We accept and enter orders. All transactions are sent to our

clearing firm, which executes our orders, compares them, allocates them, clears and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services only retail customers. We do not engage in any private placements. Our clearing firm is Pershing, LLC, Jersey City, NJ, Phone (201) 413-3635; Fax (201) 413-5368, or on the Internet at TUwww.pershing.comUUTT . Our clearing firm has also given us the following alternative contact number in the event it cannot be reached: (213) 624-6100.

UUOFFICE LOCATIONS Our firm’s main office is located in Lincroft, NJ. Our Lincroft Office is located at 437 Newman Springs Road. Its main telephone number is (732) 758-9300. Our employees may travel to that office by means of foot, car, train and bus. We engage in order taking and entry at this location.

UUALTERNATIVE PHYSICAL LOCATION(S) OF EMPLOYEES

UUCUSTOMERS’ ACCESS TO FUNDS AND SECURITIES Our firm does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm, 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, and if our Web access is available, our firm will post on our website that customers may access their fund and securities by contacting Pershing Customer Service by Fax at (201) 413-5368. The firm will make this information available to customers through its Disclosure Policy. If SIPC determines that we are unable to meeting our obligations to our customers or if our liabilities exceed our assets in violations of SEC Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books and records that identify customer accounts subject to SIPC regulations.

In the event of an SBD, we will move our staff from affected locations to the closest of our unaffected office locations: 847 Broadway, Bayonne, NJ 07002 871 Poole Avenue, Hazlet, NJ 07730 (Generator backup available)1704 Maxwell Drive, Suite 203 Wall, NJ 07719 (Generator backup available) If none of our other office locations are available to receive those staff, staff will be directed to use VPN to the backup systems.

UUDATA BACKUP AND RECOVERY (HARD COPY AND ELECTRONIC)

UUFINANCIAL AND OPERATIONAL ASSESSMENTS

1. Operational Risk

In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter parties, and regulators. Although the effect of an SBD will determine the means of alternative communication, the communications options we will employ will include: our Web site, telephone voice mail, secure e-mail. In addition, we will retrieve our key activity records as previously described in Data Backup and Recovery (Hard Copy and Electronic).

2. Financial and Credit Risk

In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue

Our firm maintains its primary hard copy books and records and its electronic records at 437 Newman Springs Road, Lincroft, NJ. Tammy Case, CCO, and Thomas P. Hyland, President, are responsible for the maintenance of these books and records. Our firm maintains the following document types and forms that are not transmitted to our clearing firm: Delivery/Prospectus Receipts, Low-Priced/Speculative Stock Disclosure Forms, and other general correspondence. The firm backs up its electronic records daily by an automated program, and keeps a copy in cloud storage, as well as a secondary cloud redundancy. In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our backup site. If our primary site is inoperable, we will continue operations from our backup site or an alternate location. For the loss of electronic records, we will either physically recover the storage media or electronically recover the data from our backup site or, if the primary site is inoperable, continue operations from our backup site or an alternate location.

to fund our operations and remain in capital compliance. We will contact our clearing firm, critical banks, and investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notification with our regulators and immediately take appropriate steps.

UUMISSION CRITICAL SYSTEMS Our firm’s mission critical systems are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking and entry. Our clearing firm provides, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. Our clearing firm contract provides that our clearing firm will maintain a business continuity plan and the capacity to execute that plan. Our clearing firm represents that it will notify us of any material changes to its plan that might affect our ability to maintain our business and presented us with an executive summary of its plan, which is attached. In the event our clearing firm executes its plan, it represents that it will notify us of such execution and provide us equal access to services as its other customers. If we reasonably determine that our clearing firm has not or cannot put its plan into place quickly enough to meet our needs, or is otherwise unable to provide access to such services, our clearing firm represents that it will assist us in seeking services from an alternative source. Our clearing firm represents that it backs up our records at a remote or, preferably, out of region site. Our clearing firm represents that it operates a backup operating facility in a geographically separate area with the capability to conduct the same volume of business as its primary site. Our clearing firm has also confirmed the effectiveness of its backup arrangements to recover from a wide-scale disruption by testing, and it has confirmed that it tests its backup arrangements twice annually.

Recovery-time objectives provide concrete goals to plan for and test against. They are not; however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure, particularly telecommunications, can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption. Our clearing firm has the following SBD recovery time and resumption objectives: recovery time period of within 4 hours, and resumption time of within the same business day. Tammy Case, CCO, will periodically review our clearing firm’s capabilities to perform the mission critical functions the clearing firm has contracted to perform for our firm. 1. UUOur Firm’s Mission Critical Systems UU

a. Order Taking:

Currently, our firm receives orders from our registered representatives via telephone, fax and manual trade entry. We do not accept any orders left on voice mail. During an SBD, either internal or external, we will continue to take orders through any of these methods that are available and reliable and, in addition, as communications permit, we will inform our representatives and customers when communications become available to tell them what alternatives they have to send their orders to us. Registered representatives and customers will be informed of alternatives by postings on our web site. If necessary, we will inform our representatives to place orders directly with our clearing firm by fax at (201) 413-5368.

b. Order Entry:

Currently, our firm enters orders by recording them on paper and electronically, and by sending them to our clearing firm electronically or telephonically. Alternatively, we place customer orders through “NetX 360”. We have contacted Pershing LLC and were advised that under its BCP, we can expect business resumption within 4 hours.

In the event of an internal SBD, we will enter and send records to our clearing firm by the fastest alternative means available, which includes telephone, fax or email. In the event of an external SBD, we will maintain the order in electronic or paper format, and deliver the order to the clearing firm by the fastest means available when it resumes operations. In addition, during an internal SBD, we may need to refer our representatives and customers to deal directly with our clearing firm for order entry.

2. UUMission Critical Systems Provided By Our Clearing Firm

Our firm relies, by contract, on our clearing firm to provide order execution, order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.

UUALTERNATE COMMUNICATIONS BETWEEN THE FIRM AND ITS CUSTOMERS, REGISTERED REPRESENTATIVES AND EMPLOYEES, UUAND REGULATORS

1. UUCustomers

We now communicate with our customers using the telephone, email, our Web site, fax, U.S. mail, and in person visits at our firm or at the other’s location. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by email but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.

2. UURegistered Representatives and Employees

We now communicate with our registered representatives and employees using the telephone, email and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. We will also employ a call tree so that senior management can reach all representatives and employees quickly during an SBD. The call tree includes all staff home, cell phone and office phone numbers. We have identified persons, noted below, who live near each other and may reach each other in person. The person to invoke use of the call tree is Tammy Case, CCO.

Caller Call Recipients Tammy S. Case Thomas P. Hyland

Jennette Fraler Melissa Masiello Nicole Olivo Theresa Nist John Moon Anthony Lopez Nicole Przybylko Carole Scanlon-Smith

Thomas P. Hyland All OSJ Principals

TFS Management Team

OSJ Principals All registered reps in their Hierarchy

3. UURegulators We are currently members of the following SROs: SEC, FINRA and NJ Bureau of Securities. We communicate with our regulators using the telephone, email, fax, U.S. mail, and in person.

In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

UUCRITICAL BUSINESS CONSTITUENTS, BANKS AND COUNTERPARTIES

1. UUBusiness Constituents

We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of an internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of an SBD to them or our firm.

2. UUBanks

We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of an internal or external SBD. The bank maintaining our Operating Account is Manasquan Bank, Wall Township, NJ. The bank maintaining our Proprietary Account of Introducing Broker/Dealers (PAIB Account) is Manasquan Bank, Wall Township, NJ. If our banks and other lenders are unable to provide the financial, we will seek alternative financing immediately from Bank of New York, Jersey City, NJ.

3. UUCounterparties

We have contacted our critical counterparties to determine if we will be able to carry out our transactions with them in light of an internal or external SBD. Where the transactions cannot be completed, we will work with our clearing firm or contact those counterparties directly to make alternative arrangements to complete those transactions as soon as possible.

UUREGULATORY REPORTING Our firm is subject to regulation by the SEC, FINRA and NJ Bureau of Securities. We now file reports with our regulators using paper copies in the U.S. mail, and electronically using fax, email and the Internet. In the event of an SBD, we will contact the SEC, FINRA and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file the required reports using the communication means available to us.

UUDISCLOSURE OF BUSINESS CONTINUITY PLAN We provide in writing a BCP Disclosure Statement to customers at account opening. We also post the Disclosure Statement on our Web site and mail it to customers upon request. Our Disclosure Statement is attached.

UUUPDATES Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm.

UUANNUAL REVIEW Our firm will review this BCP annually to modify it for any changes in our operations, structure, business, or location or those of our clearing firm.

UU

SENIOR MANAGEMENT APPROVAL I have approved the Business Continuity of TFS Securities, Inc. dated January____, 2017 as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD. By: Date: 1/18/2017

Tammy S. Case, CCO By: UU UU Date: 1/18/2017 UU

Thomas P. Hyland, President