Business Continuity Plan
We have prepared, and always maintain a current Business Continuity Plan (“BCP”) in compliance with 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. We have in place a business continuity plan that outlines essential parts of our firm's business and in detail discusses:
- Data back-up and recovery (hard copy and electronic);
- All mission critical systems;
- Financial and operational assessments;
- Alternate communications between customers and the firm;
- Alternate communications between the firm and its employees;
- Alternate physical location of employees;
- Critical business constituents, banks, and counter-party impact;
- Regulatory reporting;
- Communications with regulators; and
- How the firm shall assure customers' prompt access to their funds and securities (if applicable) in the event that the member determines that it is unable to continue its business.
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 or other localized emergency affecting our offices. Should our firm experience an internal SBD, the firm has in place alternate work locations complete with an infrastructure that would allow the firm to resume operations quickly, generally within two days. The firm acts as a third party marketer for private placements and hedge fund placements and therefore does not handle customer funds and securities or handle transactions, so there is no customer risk of access to funds during any recovery period from a business disruption.
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. Because our offices and homes are in an area remote from major population centers, the firm has low risk of a business disruption causing a large scale disruption of business operations from a large scale external SBD. Our clients already have contact information with regard to their investments and have ongoing contacts with the fund managers with which they are invested. In the event of a large scale disaster, the firm anticipates that it would generally be able to resume operations within 5 business days.
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. Please note that our firm provides an introductory service to institutions for private placement and hedge fund placements and does not participate in trading or custody of any client accounts, assets or funds. Our BCP outlines the back-up facilities and arrangements that will be utilized in the event of a business disruption. Briefly, the firm will work to restore its data and communications as outlined above and will work to reestablish its ability to provide its services. During the recovery period, clients may have access to firm personnel and information via phone and alternate electronic communications. 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.