Richfield Orion International, Incorporated Business Continuity Plan

Richfield Orion International Incorporated has developed a Business Continuity Plan. If, after reading the following, I have questions about ROI’s Business Continuity Plan, I can contact ROI at (720) 231-4103. Otherwise, I acknowledge that I have read and understand the following information concerning ROI’s Business Continuity Plan. *See Address Below*

Business Continuity Plan
[FINRA Rule 3510, FINRA Notice to Members 04-37]
The Firm has developed a Business Continuity Plan to provide procedures for response and recovery in the event of a significant business disruption. The purpose of the Plan is to identify responsible personnel in the event of a disaster; safeguard employees' lives and firm property; evaluate the situation and initiate appropriate action; recover and resume operations to allow continuation of business; provide customers with access to their funds and securities; and protect books and records. The Plan was developed considering the types of business conducted, systems critical to support business, and geographic dispersion of offices and personnel.

Implementation Of The Plan
The Plan has been designed to be implemented in the event of a disaster that results in a significant business disruption. Whether all or only parts of the Plan are implemented depends on the nature of the disruption. Generally, a significant business disruption would include: Destruction of one of the Firm's offices or facilities, whether by natural causes or by other means Loss of life or major injuries to personnel in an office location that disables that office's ability to conduct business Disruption of service from a critical service provider Disruption of service due to wide-ranging regional outages such as a power outage.

Emergency Response Team
The Firm has designated an Emergency Response Team that is responsible for implementing necessary procedures included in this Plan. The Response Team's action will depend on the nature and scope of the disruption. The "first responder" has the primary responsibility for taking action, and the "secondary responder" acts as a back-up in the event the first responder is unable to act. Where feasible, the two responders are located in different office locations.

Emergency Contact List
The Firm has established an Emergency Contact List that includes the names, phone numbers (cell and land lines), e-mail addresses, and other contact information for individuals critical to The Firm's business including key employees, key vendors or service providers, regulators, insurance carriers, banks, attorneys, and other key contacts. A copy of the List is provided to each member of the Emergency Response Team and other key personnel. This list will be reviewed and updated on at least an annual basis.

Alternative Business Locations
In the event employees can no longer conduct business at one of the Firm's office locations, the following actions may be taken: Transfer employees to the closest unaffected office location and notify personnel Transfer critical systems to another office or a back-up firm or system Transfer business operations to another Firm office unaffected by the disruption Transfer business operations to a different broker-dealer or other entity Alternative office locations have been prepared to facilitate all business transactions in the event of an emergency.

Data Back-Up And Recovery
The Firm maintains its books and records in both hard copy and electronic format. In the event of an internal or external significant business disruption that causes the loss of the Firm's records (whether hard copy or electronic records), back-up records will be recovered from the back-up site.

Clearing Firm Back-Up And Recovery
The clearing firm maintains records for The Firm under the terms of the clearing agreement. The clearing firm has developed a disaster and recovery plan to recover and retrieve records lost in a disaster affecting the Firm and/or the clearing firm. Records retained by the clearing firm are included on the Firm's Books and Records chart. The Firm has received assurance from the clearing firm that its plan is consistent with SRO rule requirements and provides adequate protection of customer funds and securities held on behalf of Firm customers and back-up and recovery systems for records retained by the clearing firm. Compliance (or another person designated to review critical third party plans) will review the clearing firm plan or a summary of the plan at least annually when the Firm's Plan is reviewed.

Mission Critical Systems
Mission critical systems are systems that are necessary to ensure prompt and accurate processing of securities transactions including order taking, entry, execution, comparison, allocation, clearance and settlement, maintaining customer accounts, and providing access to customer funds and securities.

Financial And Operational Assessments
The following describes procedures for assessing changes in operational, financial, and credit risk exposures in the event of a significant business disruption.

Operational Risk
In the event of a significant business disruption, alternative systems will be implemented to communicate with customers, employees, critical business constituents (banks, counter-parties, etc.), regulators, and other key parties depending on the nature and impact of the disruption.

Financial And Credit Risk
In the event of a significant business disruption, The Firm's financial status will be evaluated to determine the need for additional financing or identify capital deficiencies including the following: Review the impact of the disruption on the Firm's ability to conduct business Identify inability to satisfy obligations with counter-parties Contact banks or other counter-parties to secure needed additional financing Notify regulators of capital deficiencies Reduce or cease business as may be required due to capital deficiencies or inability to conduct business Transfer business to other financial institutions until the Firm may resume conducting business

Alternative Communications
The Firm may use a wide range of communication systems to communicate with its customers, employees, counter-parties, and regulators including telephone; mail; fax; e-mail; vendor systems; and personal meetings. Procedures for instituting alternative communications in the event of a significant business disruption include the following, depending on the nature of the disruption: Identify the most expedient remaining means of communication Notify employees if an off-site command center has been activated Notify employees of alternative communication systems to be used Transfer communications to another firm Determination of what communication system will be used depends on the nature of the disruption and which communication systems (electronic mail, telephone calls, etc.) are functional and the availability of personnel in the event telephone contact is necessary.

Between Customers And The Firm
In the event of a significant business disruption that disables communications systems, alternative system procedures will be implemented, including the following: Identify the most expedient remaining means of communication Notify employees regarding how to contact customers Contact customers about how to enter orders, how to access accounts and account assets, and other alternative business operations.

Between The Firm And Its Employees
In addition to the above, the Firm has developed a system to enable senior management to contact employees in the event of an emergency. The system may include, depending on geographic dispersion of employees: Contact lists maintained by managers at branch offices "Call trees" that provide for contact initiated at senior management level and pyramiding down to reach all personnel A central list of all personnel and their contact information ROI Associate Directory on the ROI Associate Support website

Between The Firm And Regulators
Communications with regulators will be conducted using the most expedient available communication system. The designated Response Team person will contact regulators regarding any major business disruption and plans for continuing business.

Business Constituent, Bank, And Counter-Party Impact
This section describes business continuity procedures regarding third parties that are critical to the conduct of The Firm's business. In most instances, contracts with critical third parties will include assurances regarding the third party's disaster recovery plans. A disruption impacting the Firm's ability to conduct business may occur either at the Firm itself or at the third party.

Business Constituents
Determine whether the third party is able to continue providing critical services. If not, identify and contact an alternate third party to provide services.

Banks And Other Financial Institutions
Determine whether the bank/financial institution is able to continue providing banking services and financing. If not, identify and secure alternative banking services and financing.

Critical Counter-Parties
Determine whether transactions may be completed with counter-parties. If not, contact clearing firm or counter-party directly to make alternative arrangements to complete transactions.

Other Obligations To Customers
Accepting Customer Orders
In the event the Firm's systems for accepting customer orders are disrupted, alternative systems will be communicated to customers and to employees including, where appropriate: Accepting orders by telephone or other alternative means Communicating orders to trading desks (internal or external) or order execution systems by telephone or other alternative means

Prompt Access To Funds And Securities
When customer access to funds and securities is impacted by a significant business disruption, customers will be notified by whatever expedient means is available (telephone, e-mail, etc.) regarding who may be contacted to request funds or securities. If ROI is unable to continue business operations, customers will be notified of an alternative financial institution where they may conduct business and access their funds and securities.

SIPC Liquidation
In the event SIPC liquidation of the Firm's business is required, designated personnel will work with the SIPC-appointed trustee to wind down the Firm's operations and transfer customer funds and securities.

Disclosure Of Business Continuity Plan
[FINRA Rule 3510(3)]
Information about the Firm's Business Continuity Plan is provided to customers as follows:
At the time of account opening on the Firm's web site www.richfieldorion.com

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