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FINRA
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BCP Disclosure Statement
The
firm has created a Business Continuity Plan (BCP) that provides for the firm
to continue client service within a reasonable amount of time, given the
scope and severity of a significant business disruption (SBD).
The BCP anticipates responding to both internal and external SBDs. An
internal SBD, such as the loss of our telephone system, affects only the
firm. The firm will respond to internal SBDs by re-routing calls to
secondary numbers, and/or relocating its primary office to a secondary
location, and/or, recovering data from a back-up storage media and/or a
back-up site. The firm expects to recover from an internal SBD within one
hour.
An external SBD, such as a power outage or flood, affects multiple
businesses and can be local, regional, national, or global. The firm’s
response to an external SBD relies more heavily on other organizations, such
as the clearing firm and product sponsors. The firm expects to recover from
an external SBD within six hours.
In the event a SBD prevents customers from contacting the firm by using the
firm’s primary phone number, fax number, or email address, customers may
contact the firm by using the following secondary contact information:
secondary phone: (800) 743-7965
secondary fax: (949) 470-0707
secondary email:
If a SBD disrupts both the primary and secondary methods of contacting the
firm, customers should contact the clearing firm at (312) 663-7500 and/or
product sponsors at the number provided on quarterly statements.
The clearing firm and/or product sponsors maintain customer accounts and can
deliver funds and/or securities. In the event an SBD renders the firm unable
to receive customer orders, the firm will instruct the clearing firm and/or
product sponsors to provide customers with instructions and assistance on
how customers can gain prompt access to their funds and securities. If the
SBD disrupts the clearing firm’s systems, customer orders and requests for
funds could be delayed during the time period in which the clearing firm
restores its operations and resumes accepting customer orders and completing
existing orders. The clearing firm expects to resume accepting orders within
one day.
While no contingency plan can eliminate all risk of service interruption or
temporarily impeded account access, the firm continually assesses and
updates its BCP to mitigate all reasonable risk.
This disclosure is subject to modification.

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