Business Continuity Plan
Client Disclosures
Introduction
This information is to provide you with very important information about Global Hunter Securities, LLC’s (“GHS” or the “Firm”) Business Continuity Plan (“BCP”) so that you are aware of what you need to do in the event that our firm experiences a significant business disruption (“SBD”). As a result of our ever-changing and evolving world, it has become necessary for firms in the financial services industry to take steps to ensure their preparedness to meet customer needs and resume regular business operations in a timely manner in the event of an SBD.There are several types of SBDs varying in severity and scope that may occur on an internal or external level. An internal SBD, such as a fire in our building, would only affect the firm’s ability to conduct its normal business. An external SBD, such as an earthquake, regional power outage, or terrorist attack, would affect the operations of several firms or the financial markets as a whole.
On April 7, 2004, the Securities and Exchange Commission (“SEC”) approved FINRA Rule 3500 series, which require FINRA members, including GHS, to establish emergency preparedness plans and procedures. Rule 3510 requires each member to create and maintain a BCP and enumerates certain requirements that each plan must address. The Rule further requires members to update their BCP’s upon any material change and, at a minimum, to conduct an annual review of their BCP. Each member also must disclose to its customers how its BCP addresses the possibility of a future BSBD and how the member plans to respond to events of varying scope.
Firm Policy
Our policy is to respond to an SBD in a manner that prioritizes the immediate safety of our employees, preservation of the firm’s property and a quick recovery in order to meet the business needs of our clients. If we determine that the SBD has been catastrophic to the level that we are unable to continue our business, we will ensure that our clients have prom pt access to their funds and securities.Alternate office location
In the event that the main office becomes inoperable, the Firm will shift its operations to its designated back-up facility, which is reasonably distant from the main office so as to reduce the chance that it will be affected by the same SBD, yet close enough to relocate to quickly if necessary. All of the Firm’s employees are familiar with the back-up facility and have been provided with driving directions.Back-up books and records
GHS maintains back-ups of all its client files and other internal books and records at an off-site facility. Should an SBD cause our primary records to be inaccessible or destroyed, we have procedures in place to access the back-up files and implement them promptly in order to assure the least possible impact on our clients.Third party business relationships
GHS has business relationships with several entities which we rely on for varying services. These entities include our clearing firm, banks, telecommunications providers and other. We have contacted our essential third parties to asses the impact that various types of SBD's may have on the services we are provided by them. Based on that information, we have been able to develop alternate plans to counter any interruptions in services that we may experience during an SBD.Key systems
The firm has identified the possibility of a loss of functionality of the systems relied upon for our regular business operations in the event of an SBD. We have enumerated our key systems in our BCP, identified the individual(s) responsible for them, and developed procedures to switch to alternative systems should our primary systems become incapacitated. Based on the trial conversions we have run, we expect minimal down time if a situation arises which forces us to switch to our alternative systems.Potential SBD Scenarios
In an effort to prepare for the variety of effects that different types of SBD's might have on GHS, we have outlined some SBD scenarios and the corresponding actions the firm will take in order to ensure that the SBD has the least possible impact on the firm and on you, our clients. We are aware the the exact ramifications of any type of SBD cannot be accurately predicted and in the event of an SBD, we will take the time to assess the firm's exact resulting situation and take the necessary steps as described in our BDP to handle the situation a effectively as is possible under the circumstances we encounter.Illustration #1 -- Internal SBD
In the event that a fire consumes GHS' main office, destroying all hardware and files, after assuring the safety and well-being of our employees, the following actions will be taken:Effects of SBD |
Action to be taken |
Personal computers, servers and data storage hardware are destroyed |
Acquire new computers, transport them to alternate location, and install the necessary software obtained from off-site storage facility. Contract network service provider if necessary to re-establish technological infrastructure and web services. |
Books and records are destroyed |
Obtain back-up books and records from off-site facility and transport them for immediate use to the alternate location. |
Office is destroyed |
Relocated to the alternative location and establish operations. Once business has resumed and is fully operational, start searching for a new main office location. |
Telecommunications hardware is destroyed |
Contact service provider to transfer existing service to the alternative location, arrange for necessary hardware and software installations. |
Illustration #2 -- External regional SBD
In the event that an earthquake or other natural disaster causes structural damage to our building and the buildings of some of our service providers, including our clearing firm, GHS will make the following assessments and take the following steps:| Effects of SBD | Action to be taken |
Building is not structurally sound |
All vital equipment and files will be transported to the alternative location and business will resume promptly. If the equipment and files are damaged beyond use, new equipment (as necessary) shall be obtained and the Firm’s back-up files shall be retrieved from our off-site storage facility. |
Clearing firm has been forced to relocate to its secondary business location |
Contact the clearing firma and assess the repercussions of its relocation on its business. Determine which method will be the most effective for delivering customer orders and requests for withdrawals to the clearing firm. |
Other vendors are experiencing service interruptions |
Contact vendors to determine when they anticipate being fully operational and make arrangements for the continuance of service, if possible, in the meantime. |
Depending on the impact of this particular type of SBD on our third-party vendors, we estimate a range of forty-eight (48) to seventy-two (72) hours for the firm to resume normal business operations.
Illustration #3 -- Catastrophic SBD
In the event of an SBD on the level of a terrorist attack, major natural disaster, political crisis, or other event this is of a magnitude great enough to force the close of the markets but does not physically affect GHS, the firm will take the following steps:Effect of the SBD |
Actions to be taken |
The financial markets are closed (other than normal market holidays) |
Communicate the situation to clients and assure that the clearing firm will be able to process transactions when the markets re-open. |
One of GHS’ banks has been significantly affected and cannot continue its business for a prolonged (more than seventy-two hours) period of time |
Contact the bank to determine how funds may be withdrawn and transfer the funds to another account. If funds are frozen for an uncertain amount of time, assess the Firm’s financial situation and pursue additional financing if necessary. |
The Firm’s investments in the financial markets are frozen |
Perform a risk assessment based on the overall status of the SBD to decide how to best preserve the Firm’s capital position under a variety of market re-open scenarios. |
There is a possibility of further BSBDs resulting from the primary SBD |
Test the Firm’s procedures for handling an SBD that results in the Firm’s relocation. Assure that back-up systems, hardware and files are ready to be utilized and can be set up quickly if needed. |
It is virtually impossible to predict a recovery time for this category of SBD due to the scope and the myriad ramifications on the financial services industry as a whole. We are confident that with the procedures we have in place that we will be able to ensure the least possible impact on our clients.
Important Contact Information
Global Hunter Securities, LLC
601 Poydras Street, Suite 2025
New Orleans, LA 70130
Telephone: (504) 527-0333
Fax: (504) 212-1610
For Additional Information about our BCP
Should you have any questions about our BCP or about this notice, please contact us at (504) 527-0333.