BCP 12.14.2007

 (we have to date everything now for any change and save the old BCP)

After 9/11, we have implemented the following Business Continuity Plan.

Since as of now, we are only a one person firm, the safety and health of that person is of paramount importance, both to the firm and it’s customers.  See the NASD Contact System.

The principal of the firm drives to and from work in a Dodge 4X4 Truck with a big 360 engine in it with a short bed.  The tires are 265/70/16 to raise the truck up for visibility purposes.  We also have installed Ranch Hand bumpers on both the front and rear of the truck.  On the front, we have the Bullnose Front Bumper and in the rear, we have the Cowboy Bumper with 10,000 pound towing capacity with a bolt in receiver tube.  There is ½” plate steel back there to protect the principal and it has been enhanced by a drop down ugly extended 2” chrome trailer hitch.  This truck is generally parked by a brick wall, which protects the principal when he gets out of the truck and walks 20’ feet to a 48” high 1”X6” redwood gate mounted on 4X4 posts set in concrete.  The gate is of a double swinging nature with about 22” to the side.

Then the principal walks another 30’ under a 20’ tall yaupon holly to 17 concrete aggregate steps 36” wide with steel handrails on both sides, which take him to the second floor of 2535 A Cedar Springs.  While he walks under a 20’ tall yaupon holly for about 12’ and all 17 steps, he can be shit on by the birds.  We have never discovered a way to protect him from them.  The “A” stands for above or “Angel.”  The principal uses the same method of entry as we were audited for in our Y2K audit.  Our landlord is Bob Spurgin who can be reached around the corner at 2521 Cedar Springs.  His telephone #  is 214-871-3322.  We have a month to month rental handshake agreement, which so far is 18 years old. 

We then proceed to our office.  There we are currently running an office made computer by b3, his first homemade computer!!!:

Thermalake Tusnami black computer case (it is the proverbial black box)

Antec HeHo 550 watt power supply

AMD 64 x2 4400 toledo chip

ASUS International mob a8n-sli premium

ASUS International 256 SLI video card

Crucial ballistic 2-1gig self cooling memory chips

Western Digital Hard Drives 2-74gig 10k rpm

Mattrox Hard Drive 1-80gig 7200rpm (because we had it)

Ext WDHard Drive 160 Gig for emails

Sony super duper cd all everything

We will use Linux SUSE 10.0 as our operating system, we tried but stayed with Micosoft, but not Vista yet.  We do have passwords to get to our clearing firm, but they change every 6 weeks or so.

Copies of financial and customer material, my ACT contact management files, are burned to a cd and transported to 429 Country View, Garland, TX 75043, 972.681.2392, via the above previously described vehicle.  Now, our home phone system is on Time Warner Cable, so we are still subject to the cable company operating. The route taken is never known in advance.  The home computer is another workstation by b³ from the left over parts he had from making his first computer. 

We connect via Time Warner Cable to our clearing firm.  Checking with www.Toast.net we find that it is currently running at 3,612 mKb.  WE DO NOT DISCLOSE OUR IP ADDRESSES, as we intend to put our business continuity plan on our website.  Our cable company Comcast may be reached at Box 650063 Dallas, TX 75265-0063.  Good Luck!

Our secondary location mentioned above is guarded by Apex Protection Service LLC.  We also have locked doors, by Baldwin Lockset hardware.  We utilize a room of the house for all of my business dealings, but this room is shared with my wife, as Texas is a community property state.

We use City of Dallas Water, Uniden and Vonage for our telephone service, and Texas Utilities for our electricity.  We currently have no gas, but hope to soon.  We have just installed a commercial Broan “Rangemaster” ventahood in our office and we hope to convert from electricity to gas for cooking purposes.  We currently use an electric Jenn-Air stove.

We will attempt to communicate with our clearing firm via our relationship manager, Chris Cervantes, but he has not disclosed to us where he lives. 

Our CPA is Krempein & Willingham as per our audits filed.  Their address is 14920 Preston Road #404 Dallas Tx 75254 469.222.3990.  In the event that we determine we are unable to continue business, we will assure customers prompt access to their funds and securities.  Our relationship manager with SWS is Chris Cervantes, office.214.859.1800, fax.214.859.6026.

Bullish Bob Bagley has the authority to execute and review the annual BCP.

Our BCP will be on our website.  Future reviews will be in a file in our office.

Our business is a profitable business.  We deal with retail customers and anyone else we can.  Please see our Membership Agreement rather than retyping all that.

Our firm is a correspondent.  As a lot of previous messages have stated, we do not maintain custody of customers’ funds or securities.  See SWS in the event you can’t reach us.

As regards SIPC, we have already suffered through one clearing firm, MJKI, failure.  SIPC is in our opinion the only good thing the customer has going for them.  We have seen the failure of May Financial locally and experienced MJKI up close and personal.  We have absolutely no input on the management of SWS.

SWS is our only mission critical component.  Like MJKI, SWS will either be working or it won’t.  If not, all we both have is SIPC.  For the customer’s information, my business account is not insured by SIPC.  It can’t be insured at all.  If SWS fails like MJKI did, BBBSI looses.  When we conclude this present investment strategy we are pursuing, we intend to take delivery of all of our securities and keep all of our money in our bank account.  We may also dramatically try to reduce our capital in our firm as this is a risk we do not wish to take. 

We enter our orders on the CSS system of SWS.  If that is down, we call in orders and confirm executions via the phone if you can get in. 

We now communicate with our customers using the previously mentioned utilities.  If the business disruption is bigger than they can handle, please come by my home and we will be glad to visit with you.

Our bank is down the street and if we can’t get here, we can’t get there either.  The management of our bank leaves a great deal to be desired anyway.  Our officer, who was less than impressive, just left and the new one hasn’t arrived yet.  Besides we don’t borrow from the bank anyway.  The bank is WAMU.  Vu Ho is our contact, office.972.271.4611, fax.972.271.4613.  We used to carry our Anti-Money sniffer dog into the bank so often, Vu Ho was smitten by our adopted greyhound that he adopted one himself.  Vu Ho likes to bring his dog, Carly by to play with our Serena at my office, but

I am very careful about letting Serena mess with his Ho dog.

We will also attempt to communicate with our District 6 regulator.  Our NASD contact is currently, Robert Falkenberg, office.972.701.8554, fax.972.716.7646, at 12801 N Central Expressway #1050 Dallas, TX 75230.  We will attempt to contact him via our Time Warner phone from home, or our Uniden/Vonage phone from the office.  Since we are VOIP, our communications are entirely dependent on Time Warner.

We will file our Regulatory Reports as best we can, assuming we are entitled to do so.

We do not intend to provide a BCP to each new customer.  At some point common sense has to prevail in the business world and since we only do business with reasonably prudent men or women, that is the only yardstick that we are going to try to meet.  Everybody and their dog sent out Y2K disclosures including my dentist.

We do not intend to bore investors with our BCP, unless they ask.  If they request a copy of our plan, we will be glad to provide it.  Recently at a continuing education seminar by our local NASD District, we were emphatically told that not all of you have access to a computer at home, or a friend’s, or a neighbor’s, or work, or the local library, so we should be prepared to read you our BCP.  We merely request that you meet us on the stoop of our veranda on the 2nd 100* degree day in July or August at 4 p.m. CST, DST, so that we may read you our BCP as you stand on the stoop in the wonderful sunshine.  We suggest you wear a broad brim hat, sunscreen, and bring bottled water.  We will stand in the shade of the veranda, under the ceiling fan, and slowly read to you our BCP.  Please be apprised that we are a graduate of the State of Texas public school system, so do not criticize our reading ability please!

In summation, your records with me are as safe as they are with your lawyer, doctor, dentist, cpa, veterinarian, or any other licensed professional, who for whatever reason(s) stops doing business.  We cannot do anything with our clearing firm.  We cannot do anything with our utilities, both Time Warner or TU Electric.  We can get along with our landlord to point that for 17 years we have not had a lease.  A very large number of you have been doing business with us for over 17 years.  We like it.  We hope you do too!

We will update this plan in the event of any material change and do an annual review within 60 days of our fiscal year end, which is 09.30.

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.

Bullish Bob

Chief Compliance Officer