A. 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 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.

B. Approval and Execution Authority
Peter Schiff, President, a registered principal, is responsible for approving the plan and for conducting the required annual review. Peter Schiff has the authority to execute this BCP.

C. Plan Location and Access
Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on www.europac.server.net in Michael Carroll Files under: My Documents: Business Continuity Plan.wpd, and with Doug Cooper of CoopLink Computer Support Services.

A. Office Location #1: Darien, CT
Our Location #1 Office is located at 10 Corbin Drive, Suite B, Darien, CT 06820. Its main telephone number is 800-727-7922. Our employees may travel to that office by means of car, train, or bus. We engage in order taking and entry at this location.

B. Office Location #2: Newport Beach, CA
Our Location #2 Office is located at 4667 MacArthur Blvd., Ste. 450 Newport Beach, CA 92660. Its main telephone number is 800-993-8350. Our employees may travel to that office by means of foot, car, train, or bus. We engage in order taking and entry at this location.

C. Office Location #3: Phoenix, AZ
Our Location #3 Office is located at 5110 N. 44th Street Suite L200 Phoenix AZ. 85018. Its main telephone number is 800-727-6435. Our employees may travel to that office by means of foot, car, train, or bus. We engage in order taking and entry at this location.

D. Office Location #4: Medford, OR
Our Location #4 Office is located at 3560 Excel Drive, Suite 103, Medford, OR 97504. Its main telephone number is 877-740-0174. Our employees may travel to that office by means of foot, car, train, or bus. We engage in order taking and entry at this location.

A. 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 effects of an SBD will determine the means of alternative communication, the communications options we will employ will include www.europac.net. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).

Rules: NASD Rules 3510(c)(3) & (f)(2).

B. Financial and Credit RiskIn the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue 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 notices with our regulators and immediately take appropriate steps, including funding Net Capital through Mr. Schiff's Brokerage account holdings.

Rules: NASD Rules 3510(c)(3), (c)(8) & (f)(2).

A. Our Firm's Mission Critical Systems

1. Order Taking
Currently, our firm receives orders from customers via telephone/fax/e-mail and at in person visits by the customer. 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 customers when communications become available to tell them what alternatives they have to send their orders to us. Customers will be informed of alternatives by letter, telephone, email or fax. If necessary, we will advise our customers to place orders directly with our clearing firm at Pershing, LLC, 201-413-3664.

2. Order Entry
Currently, our firm enters orders by recording them on paper and electronically and sending them to our clearing firm electronically or telephonically. We also place customer orders through Net Exchange Pro, a Pershing Proprietary System. We have contacted Pershing, LLC and were told that, under its BCP, we can expect services 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 include mail, 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 customers to deal directly with our clearing firm for order entry.

B. Mission 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.

Rules: NASD Rules 3510(c) & (f)(1).

A. Our Firm's Mission Critical Systems

We now communicate with our customers using the telephone, e-mail, 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 e-mail 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.

Rule: NASD Rule 3510(c)(4).

B. Employees

We now communicate with our employees using the telephone, e-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. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home 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: Peter Schiff

Caller	Call Recipients
Peter Schiff	Michael Carroll, Michael Freedman, Pat McDonald
Michael Carroll	Avdul Demiri, Angela Macaluso, Shanay Taylor, Ed Schweitzer, Lewis Kasowitz, Dan Mahony, Marlon Varsace, James Phipps, David Paris, Bruce Oderman, Eric Steingruebner, John Catalfio, Will Reishman, Carl Hayden
Eric Steingruebner	Jeff Brack, Howard Shelly, Danielle Dwyer-Psarras, Burt Gardner, Jessica Lorge, Laura Reiter, Chris Reiger, Lo Phouma
John Catalfio	Jason Farkas, Brian Holden, Mike Masunas, Brian Holden, Alan Walicki
Will Reishman	Betsy Daley, Paul Princen
Carl Hayden	Mark Anderson

Rule: NASD Rule 3510(c)(5).

C. Regulators

We are currently members of the following SROs: NASD, SEC, Connecticut Department of Corporations. We communicate with our regulators using the telephone, e-mail, 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.

Rule: NASD Rule 3510(c)(9).

A. Business 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 the 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 a SBD to them or our firm. [or we have entered into a supplemental contract with certain critical business constituents to provide such services. The alternative suppliers are disclosed below.] Our major suppliers are: Staples and Office Depot.

Rules: NASD Rule 3510(c)(7).

B. Banks

We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of the internal or external SBD. The bank maintaining our operating account is: Bank of America, Darien, CT 1120 Post Road (Route 1), Darien, CT 06820. The bank maintaining our Proprietary Account of Introducing Brokers/Dealers (PAIB account) is Bank of New York, 100 Wall Street, New York, NY 10021. If our banks and other lenders are unable to provide the financing, we will seek alternative financing immediately from Peter Schiff's personal brokerage account at Pershing LLC, account number: 6WU207721.

Rules: NASD Rule 3510(c)(7).

C. Counter-Parties

We have contacted our critical counter-parties, such as other broker-dealers or institutional customers, to determine if we will be able to carry out our transactions with them in light of the internal or external SBD. Where the transactions cannot be completed, we will work with our clearing firm or contact those counter-parties directly to make alternative arrangements to complete those transactions as soon as possible.

Rules: NASD Rules 3510(a) &(c)(7).