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Date: March 1, 2006
We have prepared, and always maintain a current Business Continuity Plan (“BCP”)
in compliance with FINRA Rule 3510. This document outlines our plans to continue
business and meet our existing obligations to customers in the event of a Significant
Business Disruption (“SBD”). Our BCP is summarized below:
Our firm’s policy is to respond to a SBD by safeguarding employees’ lives and firm
property, making a financial and operational assessment, quickly recovering and
resuming operations, protecting all of the firm’s books and records, and allowing our
customers to transact business. We will make every reasonable effort to meet our
obligations to customers at all times.
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.
In the event that we determine we are unable to continue the normal conduct of our
business, due to any of the scenarios described above, or any other circumstances, we
will enact our BCP in order to assure customers prompt access to their funds and
securities. Our BCP outlines the back-up facilities and arrangements that will be utilized
in these circumstances.
We will make every reasonable effort to continue the conduct of business during any
SBD, employing the use of our BCP. We plan to continue the conduct of business during
any SBD unless circumstances prohibit us from doing so.
If, for any reason, at any time, we are forced by circumstances outside our direct control
to discontinue business, we will immediately determine our planned recovery time and
communicate those plans to all concerned parties.
Our BCP is subject to modification, update, and improvement at any time so that we may
constantly assure ourselves, our customers, and any other concerned party of our
readiness to confront a SBD. |
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