Disclosure Statement

Saperston Asset Management, Inc.’s Business Continuity Plan

Saperston Asset Management, 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.  With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – During a significant business disruption, Saperston Asset Management, Inc. will re-establish telephone service with our clients as soon as possible. Our clients should check our website at www.saperston.com for our latest information.

As a client of Saperston Asset Management, Inc. we recognize you may need access to your account to sell a position or request a check before we re-establish telephone service. During this time, Brighton Securities (Our introducing firm) and First Clearing, (Our clearing firm) will assist you with sell/liquidation orders and provide check disbursements, if needed. If you cannot contact our firm, please call Brighton Securities at 800-388-1703 or WFCS (First Clearing) for assistance at 877-496-3223.

If you cannot contact us as you usually do at 716-649-9800 or 716-854-7541 or 800-879-7541, you should call us at 716-598-6568, 716-867-8965, 716-583-5339, 941-359-2604 or go to our web site at www.saperston.com for further information.

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 backup 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.

Our clearing firm, First Clearing, LLC, 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 a reasonable amount of time.  Your orders and requests for funds and securities could be delayed during this period. 

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 coordinate with our introducing and clearing firm when needed and expect to recover and resume business within 24 hours depending on the severity of the disruption.  In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area if at all possible and recover and resume business as soon as we can.  In either situation, we plan to continue in business, transfer operations to our introducing firm (Brighton Securities) or our clearing firm (First Clearing) if necessary, and notify you through the phone numbers listed above or our web site www.saperston.com.  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 716-649-9800 or go to www.saperston.com to contact us. (01-2023 update)