TRADERFIELD SECURITIES INC.
109 LAFAYETTE STREET SUITE 503
NEW YORK, NY 10013
TELE. 212-966-9550
FAX 212-941-7819
TRADERFIELD SECURITIES INC.
BUSINESS CONTINUITY PLAN (BCP)
Our firm’s two emergency contact persons
are:
Patrick Lee, President, 917-921-1692, Traderfield@mytraderfield.com
Cindy Wu, Manager, 718-938-6266, Traderfield@mytraderfield.com
These names will be updated in the event of a material change, and Executive Representative will review then within 17 business days of the end of each quarter.
The firm will provide FINRA with the contact information for the two emergency contact persons:
Patrick Lee, President, 109 Lafayette St. STE 503 NY, NY 10013, 917-921-1692, fax 212-941-7819 Traderfield@mytraderfield.com and
Cindy Wu, Manager, 109 Lafayette St. STE 503 NY, NY 10013, 718-938-6266, fax 212-941-7819 Traderfield@mytraderfield.com
through the FINRA Contact System (FCS). Patrick Lee will promptly notify FINRA of any change in this information through FCS (but no later than 30 days following the change) and will review, and if necessary update, this information within 17 business days after the end of each calendar year.
Our firm’s policy is to respond to a Significant Business Disruptions (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.
Our plan anticipates two kinds of SBDs, internal and external.
Internal SBDs affect only our firms ability to communicate and do
business, such as a fire in our building.
External SBDs prevent the operation of the securities markets or a number
of firms, such as a terrorist attack, a city flood, or a wide-scale, regional
disruption. Our response to an external SBD relies more heavily on other organizations and systems , especially on the
capabilities of our clearing firm.
Patrick Lee, President, is responsible for approving the plan and for
conducting the required annual review.
Patrick Lee, President has the authority to execute this BCP.
Our firm will maintain copies of its BCP plan and the annual reviews,
and the changes that have been made to it for inspection. We have Given FINRA, NY a copy of our
plan. An electronic copy of our plan is
located on MYTRADERFIELD.COM.
Our clearing firm is :
Penson Financial Services, Inc.
1700 Pacific Avenue, STE 1400
Dallas, TX 75201
214-765-1009
Correspondent Desk: (800) 221-3524
Our firm does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm, Penson Financial. 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. The firm will make this information available to customers through its disclosure policy.
If SIPC determines that we are unable to meet our obligations to our
customers or if our liabilities exceed our assets in violation of Securities
Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our
assets to customers. We will assist SIPC and the trustee by providing our books and records identifying customers
accounts subject to SIPC regulation.
VII.
Data Back-Up and
Recovery (Hard Copy and Electronic)
Our firm maintains its
primary hard copy books and records and its electronic records at 109 Lafayette
St. Suite 503, NY NY 10013. Patrick Lee , President, telephone number
212-966-9550 is responsible for the maintenance of these books and records.
Our firm maintains its back-up hard copy books and records at 17 Apple
Blossom Lane, Manalapan, NJ 07726. These records are focus report copies and
quarterly monthly statements. Patrick
Lee, President, 212-966-9550 is responsible for maintenance of these back-up
books and records. Our firm backs up
its paper records by copying and taking them to our back-up site. We back up our records quarterly.
The firm backs up its electronic records quarterly by maintaining focus
report records and storage of customers’ monthly statement in disk, and keeps a
copy at 17 Apple Blossom Lane, Manalapan, NJ
07726.
In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our backup site. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.
In the event of an SBD, we will immediately identify what means will
permit us to communicate with our customers, employees, critical business
constituents, critical banks, critical counter-parties, and regulators. Although the effects of an SBD will
determine the means of alternative communication, the communications options we
will employ will include 732-866-9437, 917-921-1692, traderfield@mytraderfield.com. In addition, we will retrieve our key
activity records as described in the section above, Data Back-Up and Recovery
(Hard Copy and Electronic).
In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. We will contact our clearing firm, critical banks, and investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including temporary elimination of salaries of all directors, officers and employees.
Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, the maintenance of customer accounts, access to customer accounts and the delivery of funds and securities. More specifically, these systems include Penson Financial which handle and process our orders executions.
We have primary responsibility for establishing and maintaining our
business relationships with our customers and have sole responsibility for our
mission critical functions of order taking (and) entry (and execution). Our clearing firm provides, through
contract, the (execution,) comparison, allocation, clearance and settlement of
securities transactions, the maintenance of customer accounts, access to
customer accounts, and the delivery of funds and securities.
Our clearing firm contract provides that our clearing firm will
maintain a business continuity plan and the capacity to execute that plan. Our clearing firm represents that it will
advise us of any material changes to its plan that might affect our ability to
maintain our business (and presented us with an executive summary of its plan,
which is attached). In the event our
clearing firm executes its plan, it represents that it will notify us of such execution
and provide us equal access to services as its other customers, if we
reasonably determine that our clearing firm has not or cannot put its plan in
place quickly enough to meet our needs, or is otherwise unable to provide
access to such services, our clearing firm represents that it will assist us in
seeking services from an alternative source.
Our clearing firm represents that it backs up our records at a remote
(or, preferably, out of region) site.
Our clearing firm represents that it operates a back-up operating
facility in a geographically separate area with the capability to conduct the
same volume of business as its primary site.
Our clearing firm has also confirmed the effectiveness of its back-up arrangements
to recover from a wide scale disruption by testing, and it has confirmed that
it tests its back-up arrangements every time period).
Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure- particularly telecommunications-can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption. Our clearing firm has the following SBD recovery time and resumption objectives: recovery time period of (e.g., within 4 hours); and resumption time of (e.g., within the same business day.
Patrick
Lee will periodically review our clearing firm's capabilities to perform the
mission critical functions the clearing firm has contracted to perform for our
firm.
1.
Order taking
Currently, our firm receives orders from customers via telephone and in
person visits by the customer. During
an SBD, either internal or external, we will continue to take orders through
any of these methods that are available and reliable, and in addition, as
communications permit, we will inform our customers when communications become
available to tell them what alternatives they have to send their orders to
us. Customers will be informed of
alternatives by visiting our office. If
necessary, we will advise our customers to place orders directly with our
clearing firm at :
Penson Financial
Correspondent Desk: (800) 221-3524
Trading Desk:
(800) 253-2746
2. Order Entry
Currently, our firm enters orders by recording them on paper and
electronically and sending them to our clearing firm electronically or
telephonically. Alternatively, Penson
Financial contracts with their third parties that support its mission-critical
systems maintained at a predetermined service levels.
Our clearing firm advises that within approximately 4 hours recovery of
order services and order execution services within approximately 4 hours.
In the event of an internal SBD, we will enter and send records to our
clearing firm by the fastest alternative means available, which include
messenger In the event of an external SBD, we will maintain the order in electronic or paper format, and deliver the
order to the clearing firm by the fastest means available when it resumes
operations. In addition, during an internal SBD, we may need to refer to our
customers to deal directly with our clearing firm for order entry.
3.
We do not execute orders.
4.
Other Services Currently Provided to Customer
We have no other services
currently provided to customers.
Our firm relies, by contract, on our clearing firm to provide order execution, order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.
X.
Alternate
Communications Between the Form and Customers, Employees and Regulators
We now communicate with our
customers using the telephones, U S mail and in person visits at our firm or at
the other’s location. In the event of
an SBD, we will assess which means of communication are still available to us,
and use the means closest in speed and form (written or oral) to the means that
we have used in the past to communicate with the other party. For example, if we have communicated with a
party by e-mail but the internet is unavailable, we will call them on the
telephone and follow up where a record is needed with paper copy in the U. S.
mail.
We now communicate with our employees using telephone and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers. We have identified persons, noted below, who live near each other and may reach each other in person:
The person to invoke use of the call tree is: Patrick Lee
Caller Call Recipients
Patrick Lee Cindy Wu
We are currently members of the following SRO’s: FINRA. We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.
We have no major business with which we have an ongoing commercial
relationship in support of our operating activities.
We have contacted our critical counter-parties, such as other
brokerage-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.
Our firm is subject to regulation by : FINRA and SEC. We now file reports with our regulators using paper copies in the U. S. mail, and electronically using fax, e-mail, and the internet. In the event of an SBD, we will check with the SEC, FINRA, and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.
FINRA SEC
One Liberty Plaza, 47th fl. 3 World Financial Center, STE 400
New York, NY 10006 New York, NY 10281
212-858-4232 212-336-1100
Our firm will update
this plan whenever we have a material change to our operations, structure,
business or location or to those of our clearing firm. In addition, our firm will review this
BCP
annually, on December 30, to modify it for any changes in our operations,
structure, business, or location or those of our clearing firm.
I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.
signed: ______________________________
Title : ______________________________
Date : _____________________
Updated 06/28/2010