Business Continuity Plan
Certain events may occur which impact the way our company does business, making business continuity planning essential for both you and us. When such an event has an effect that could potentially cause delays or influence our normal course of business we refer to it as a "significant business disruption" ("SBD"). Our goal as an online stock broker is to assure our continuing operation and ability to provide our customers with complete and uninterrupted access to their funds and securities. We will immediately assess each SBD and execute an appropriate plan designed to minimize the effect on our customers. Obviously such events are unpredictable, however, we have thoroughly reviewed every aspect of our current business including our physical and virtual locations, hardware, software, reliance on utilities, telephone, and internet service providers, as well as additional services provided for our web site design, development, and maintenance and other trading platforms available to our customers.
As a fully disclosed firm we rely on Apex Clearing Corporation ("Apex Clearing"), our clearing firm to perform many of the services involved in your securities transactions. Your funds and securities are held by Apex Clearing and not by us. As such, Apex Clearing has its own Business Continuity Plan, a copy of which has been received and reviewed by our firm's Compliance Department.
The impact of each SBD will be assessed immediately by the senior management of Firstrade Securities, taking into account all factors which may influence our ability or the ability of other parties upon whom we rely to continue operations. An SBD may include anything from a local power outage within our building to a more regional disruption caused by severe weather or something on a much broader scale such as a terrorist attack which has the potential to disrupt national markets.
More important than whether or not to continue operations will be to what degree we will be able to perform. Our responsibilities to our customers come first and foremost and unless a SBD is of such catastrophic proportions that prohibit reasonable market activities we will strive to work with our clearing firm and other business constituents to provide you with continued access to those markets. Please be aware that although operational, such services may not match the full capabilities normally provided; however we will consider all factors, including the size and capability of our staff, when determining which level of service to provide.
Separate from our clearing firm we have considered alternate backup facilities and multiple layers of redundancy for electronic data created and stored on our existing systems. Hard copies of your account information maintained in our files are also maintained by our clearing firm. Your account activity is maintained by Apex Clearing via redundant servers in different locations. Other proprietary information contained on our systems is backed up daily and maintained by Broadridge Vantra, our website hosting partner, which has locations across the country. We have considered these factors in conjunction with the BCPs of our major business constituents including our clearing firm in order to minimize the time you may be away from the market.
A worst case scenario involving a SBD of major proportions could cause us to cease operations altogether. However, in that event our goal will still be to protect you, our customer, and we will work with our regulator, major business constituents including our clearing firm, and the Securities Investor Protection Corporation ("SIPC").
We have considered the following scenarios when addressing our response and recovery times:
Single Building Outage
Fire, power disruptions, or other local situations could prevent us from gaining access to our building and offices. Our main office personnel who are essential to recovery will be able to access their computer systems and files from their homes. Customer phone lines will be redirected to appropriate personnel at their alternate locations including, in some cases, their homes. Our web site home page and main telephone number will have messages informing customers of the disruption and our current capacity and ability to handle their orders
New York City or Metropolitan Area Outage
Citywide conditions such as bad weather, transportation strikes, or other events could prevent many of our staff from reaching their normal work place(s). Those who are essential to recovery will be able to access their computer systems and files from their homes. In the event they reside in proximity to the disruption and are incapable of performing their role from their first alternate location, their home, we have considered temporarily locating them with other staff members who do not reside within the problem area. Our web site home page and main telephone number will have messages informing customers of the disruption and our current capacity and ability to handle their orders.
Greater New York, Tri-State, or Larger Area Outage
Events of a larger scale like those effecting our nation's security, a widespread blackout, or a blizzard could not only prevent our most local staff from performing their duties but also prevent the performance of their functions regardless of their location. Such disruptions may even impact our business indirectly due to their effect on our major constituents like our clearing firm which is physically located in the same region of the country. Like the other scenarios, our senior management will need to assess the situation and determine a proper course of action. Also like the others, our web site home page and main telephone number will have messages informing customers of the disruption and our current capacity and ability to handle their orders. If our management determines that we are capable of operating, even in a limited capacity, we will assess our immediate needs and make a best efforts determination as to our approximate recovery time. We will post this information on our web site and update our telephone message(s) accordingly.
Our BCP is subject to modifications and will be updated when certain factors influencing our business change. An updated summary will be posted to our Web site as soon as practicable. You may alternatively request a copy at any time by contacting the Compliance Department of our firm at:
Firstrade Securities Inc.
30-50 Whitestone Expwy.
Flushing, NY 11354
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