As part of our effort to offer an ongoing contingency
plan in the event of a Significant Business Disruption (SBD) ePLANNING
Securities, Inc. has developed a Business Continuity Plan (BCP.) Significant
Business Disruptions are disruptions that may occur internally or externally
that would affect our firm's ability to manage the day-to-day operation
of our business and our ability to service our customers. SBD's may
vary in severity and the level of impact on our firm. Examples of a
SBD include building fires, earthquakes and power outages. It is important
that our customers are familiar with our company's protocol for operation
in the event of a SBD.
ePLANNING has incorporated a number of procedures allowing our firm
to continue to operate and service our clients during a SBD. Our response
to an external SBD relies more heavily on other organizations and systems,
especially on the capabilities of our clearing firm. ePLANNING provides
our Business Continuity Plan Disclosure and our Trading Redundancy Procedures
to our representatives and employees on an annual basis. It should be
noted that during a SBD all clearing services, including trading and
cashiering functions, would be handled directly though our clearing
firm, National Financial Services, LLC. The representative would handle
any "Away Held" business (i.e. mutual fund company, insurance company
or custodian) through the third party vendor. When necessary ePLANNING
may temporarily relocate internal operations to the nearest functioning
branch office. In this case all branch offices will be notified by any
means available of the temporary change in procedure and will be directed
to follow the steps outlined in the BCP and Trading Redundancy procedures.
Our clearing firm, National Financial Services, LLC, has a fully functional
backup facility to handle trading, sales and operational activity. In
the event of a SBD National Financial Services, LLC will be able to
facilitate all trading, and operational services at one of their four
primary facilities. Each facility may operate as a backup site in the
event of a SBD and each facility is physically located far enough apart
from one another so that any disruption at one facility is unlikely
to affect another.
ePLANNING does not maintain custody of customer's funds or securities,
rather all customer assets are maintained at our clearing firm, National
Financial Services, LLC or other third party mutual fund and insurance
companies. In the event of an internal or external SBD, if telephone
service is available, our registered persons will take customer orders
or instructions and contact our clearing firm on their behalf, and if
our web access is available, our firm will post on our web site that
customers may access their funds and securities by contacting National
Financial Services, LLC directly at 800-877-2410, prompts 2, 1. In addition,
ePLANNING provides Trading Redundancy information to our clients and
representatives on an annual basis with the Business Continuity Plan
Disclosure. The information outlined in the Trading Redundancy Procedures
provides contact information to reach National Financial Services, LLC
directly in the event that clients and representatives are unable to
reach the home office to transact on an account. For any business held
away at a third party vendor (e.g. mutual fund and insurance companies)
the client or representative may contact the company directly to transact
on their account.
The BCP for ePLANNING addresses policies and procedures for data back
up and recovery; mission critical systems; financial and operational
systems; alternative means of communications with employees, customers
and regulators; critical business constituents; and procedures for assuring
our customers uninterrupted access to their account assets.
Our firm may communicate with our customers by telephone, e-mail, our
Web site, fax, U.S. mail, and in person visits at our firm or at the
customer's location. In the event of an SBD we will determine the best
course of action to use in effectively communicating with our representatives
and customers. Examples include posting a notification with procedures
to follow on our web site, sending out a mass distribution email and
letter though the U.S Postal Service and recording a message on our
home office outgoing voice message system. The method of communication
will depend on the most effective and efficient means that is available
to our firm for broadcasting a message to our representatives and customers.
The firm recognizes the potential for a Significant Business Disruption
(SBD) and how critical it is to have a strategy for operating the broker/dealer
during a SBD. The terms and conditions of our BCP are subject to change.
ePLANNING will review and update our BCP on no less than an annual basis.
Any updates to our BCP Disclosure will be provided to our customers
and updated on our web site. Should you require a written copy of our
BCP Disclosure or have any questions you may contact Scott Hultsman
at (888) 815-1000 x155 or by email at shultsman@eplanning.com.
|