FINRA Rule 4370 requires members to develop and maintain a written business continuity and contingency plan (BCP) and to establish procedures relating to an emergency or significant business disruption. Such procedures must be reasonably designed to enable members to meet their existing obligations to customers. In addition, such procedures must address their existing relationships with other broker-dealers, and counter-parties. Furthermore, each member must disclose to its customers how its business continuity and contingency plan addresses the possibility of a future significant business disruption and how the member or member organization plans to respond to events of varying scope. At a minimum, such disclosure must be made in writing to customers at account opening, posted on the Internet Web site of the member or member organization and mailed to customers upon request.
Susquehanna Financial Group, LLLP (SFG) has established a BCP which envisions several potential business disrupting scenarios: 1) events that are specific to a single SFG office; 2) events that disrupt its corporate headquarters; and 3) events that disrupt SFG’s clearing firm. In each scenario SFG will implement plans designed to ensure that customers are able to contact the firm and have access to funds, securities and critical records.
In the event that any of the offices cannot be inhabited, SFG would redirect crucial staff members to one of the still-functioning offices. Staff in the functioning offices would take over sales, execution, and support responsibilities until relocations are complete.
SFG anticipates that the recovery time for a disruption to a single satellite office is within half a day. SFG anticipates that recovery time for a significant disruption to its main location would be within one week for most functions, while certain electronic trading systems may take longer. SFG’s clearing firm has represented that it maintains the necessary back-up facilities to return service in four hours for most functions.
SFG will update the BCP as needed and any material changes will be available on our Web site at www.sig.com. If you have further questions regarding our BCP please contact your SIG Brokerage representative.
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