Alamo Capital, provide financial services using computer and telephone systems. The events of September 11, 2001 emphasized the importance of the capital markets to our economy. As a result, we have been working on improving our responses to various situations that have the potential to impact our ability to serve you. This disclosure document is designed to provide you with information on how we have approached and/or plan to approach various situations that we may encounter. Overview of Alamo Capital Alamo Capital, a Member Firm of the FINRA & SIPC is a full-service brokerage firm providing customers with execution services on all major exchanges and access to all major markets. These functions are provided primarily in Walnut Creek , California with various broker, and trading systems. Alamo Capital uses various mission critical systems to provide these services to our customers.

Our business continuity planning (“BCP”) first insures the safety and security of our employees. The events of 9/11 emphasized the unique skill sets of personnel who work in our industry and the need to put their safety first so that after an interruption they are able to continue serving our customers. In addition to protecting our personnel, our BCP and daily operations are focused on preserving our critical firm and customer data through daily back ups which are then moved off-site via media and/or real time and near real time electronic copies of our data at remote locations. Our industry is heavily interconnected with data connections ranging from dial-up modem communication, dedicated private lines, and in many cases, the Internet through encrypted sessions.

Business Continuity Planning Response Scenarios

The details of our BCP are proprietary and contain information which is confidential and in many cases potentially harmful to Alamo Capital and our customers if publicly available. The following series of scenarios are presented to disclose to you our planned approach for dealing with a variety of hypothetical Significant Business Disruptions (SBD’s), but based on the number of variables present in each situation. Alamo Capital can not guarantee we will follow these procedures.

Scenario 1

An event occurs, like that of  September 11, 2001, which causes the complete shut down of securities trading, clearance/settlement or other banking services nationwide.

Alamo Capital plans to continue business during this type of event and will await the reopening of the affected institutions. Unless a securities industry holiday is declared, we plan to be open each business day until full functionality is restored. The recovery time in this scenario will be dependent on the timing specified by the impacted organizations. We plan to be ready to open when they reopen.

Scenario 2

A specific exchange is unable to trade. (nationwide)

Alamo Capital plans to continue business during this type of event and will route order flow to alternative exchanges. Our recovery time objective for this scenario is less than one hour.

Scenario 3

Our headquarters location is closed. (Single building, city wide, business district)

Alamo Capital plans to continue business during this type of event and will transfer mission critical activities to our other offices. Assuming no access to and no power to the building, the planned recovery time objective for mission critical activities is four hours.

Our planned recovery times for business resumption may be negatively impacted by the unavailability of external resources and other circumstances beyond our control.

Updates to This Disclosure

As we continue to test our plans and as conditions in our firm and the industry change, we will revise the plans as considered necessary. Whenever we update this disclosure document we will promptly place a copy of it on our website. You may request a hard copy of this disclosure in its current revision be sent to you any time by mail.

Ask Us

For more information, please either call our office at (877) 68-ALAMO – or – (877) 682-5266, fill out a brief contact form or email our office at [email protected]. In the event of an emergency and you are unable to reach us, please contact Hilltop Securities at 800-678-3792 or 214-953-4000 to obtain your account information.