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I. Emergency Contact Persons
II. Firm Policy
III. Business Description
IV. Office Location
V. Alternative Physical Location(s) of Employees
VI. Customers’ Access to Funds and Securities
VII. Data Back-Up and Recovery (Hard Copy and Electronic
VIII. Financial and Operational Assessments
IX. Mission Critical Systems
X. Alternate Communications Between the Firm and Customers, Employees and Regulators
XI. Critical Business Constituents, Banks, and Counter-Parties
XII. Regulatory Reporting
XIII. Disclosure of Business Continuity Plan
XIV. Updates and Annual Review
XV. Senior Manager Approval
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XI. Critical Business Constituents, Banks, and Counter-PartiesA. Business constituentsWe will contact our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determine the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm. Or we have entered into a supplemental contract with certain critical business constituents to provide such services. B. BanksWe will contact our banks and lenders to determine if they can continue to provide the
financing that we will need in light of the internal or external SBD. The bank
maintaining our operating account is: C. Counter-PartiesWe will contact our critical counter-parties, such as other broker-dealers or institutional customers, to determine if we will be able to carry out our transactions with them in light of the internal or external SBD. Where the transactions cannot be completed, we will work with our clearing firm or contact those counter-parties directly to make alternative arrangements to complete those transactions as soon as possible. |
| Copyright © 2012. All rights reserved. Podesta & Co. | 208 South LaSalle St., Suite 1460 Chicago, IL 60604 (312) 899-0133 |