ASPEN FINANCIAL MANAGEMENT                                            (575) 377-9404  
Building Client Trust and Confidence        
                  

Disclosures/Privacy


Disclosures


Aspen Financial Management, Inc. ("Aspen") is a state registered investment adviser with home office located in New Mexico. Aspen and its representatives are in compliance with the current filing requirements imposed upon State registered investment advisers by those states in which Aspen registered. Aspen may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. Aspen’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of Aspen’s web site on the Internet should not be construed by any consumer and/or prospective client as Aspen’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Aspen with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of Aspen, please contact the state securities regulators for those states in which Aspen maintains a notice filing. A copy of Aspen's current written disclosure statement discussing Aspen's business operations, services, and fees is available from Aspen upon written request.

Aspen does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Aspen's web site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.



BCP Summary Statement

Aspen Financial Management (Aspen) has developed and implemented a Business Continuity Plan (“BCP”) that includes redundant data centers and alternate facilities to protect its business processes and technology environment in the event of a significant business disruption. Aspen’s policy is to respond to a significant business disruption (SBD) in an effort to safeguard employees’ lives and firm property, make a financial and operational assessment, quickly recover and resume operations, protect the firm’s books and records, and allow our customers to transact business.

The plan addresses business disruptions that may be caused by a local incident or by a regional or market related disaster that applies to many companies. The Plan covers our critical business processes and related employees essential for Aspen to continue to conduct business for an interim or temporary period during a business interruption. Every important aspect of Aspen’s securities business, including data back up 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 is addressed in this plan.

Aspen’s goal is to recover its Critical Business Processes with minimal interruption, depending on the nature of the disruption. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within two hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and presume to recover and resume business within 24-48 hours. 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.

If after a significant business disruption you cannot contact us as you usually do at 575-377-9404, please use our emergency contact number 575-377-6700, or go to our website at www.aspenfm.com for contact instructions. If you cannot access us through either of those means, and you have a brokerage account carried by our clearing firm, you should contact TD Ameritrade Institutional at 1-866-983-2683 for instructions on how it may provide prompt access to your funds and securities including accepting buy and sell orders and issuing checks and wires from your account. If your account is held at a mutual fund or insurance company, you should contact the company directly for access to your securities.

Please be advised that our business continuity plan is subject to change and modification. Our firm will update this plan whenever we have a material change to our operations, structure, business, location or to those of our clearing firm. In addition, our firm will review our plan annually to modify it for any changes. If the plan is modified, we will promptly post the revised summary on our Website, www.aspenfm.com. If you have questions about our business continuity planning or would like a written copy of the summary of our BCP, you can contact us at Alan@AspenFM.com  or PO Box 113, Angel Fire, NM 87710.