Business Continuity Plan
1. Emergency Contact Persons
Our firm’s emergency contact persons are:
Jonathan Self | 404-596-5393 | firstname.lastname@example.org
These names will be updated in the event of a material change, and our Executive Representative will review them within 17 business days of the end of each quarter.
FINRA Rule 3520.
2. Firm Policy
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a Securities and operationalassessment, 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.
Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect onlyour firm’s 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 introduced firms.
Approval and Execution Authority
Jervis Hough is responsible for approving the plan and for conducting the required annual review and has the authority to execute this BCP.
Plan Location and Access
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 a copy of our plan.
3. Business Description
Jumpstart Securities, LLC is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. The firm also does not accept and enter public securities orders. Our firm makes introductions to the issuers of private placement securities.
4. Office Locations
Our Main Office is located at 3455 Peachtree Road NE, 5th Floor, Atlanta, GA 30326. This location has a dedicated high speed internet connection data and voice.
5. Alternative Physical Location(s) of Employees
In the event of an SBD, we will move our staff from affected offices to another location including the homes of the firms managers that are all equipped with internet access, as well as physical accommodations to allow business continuity.
Such information will be posted to a web site and messages will be left with all employees.
FINRA Rule 3510(c)(6).
6. Customers’ Access to Funds and Securities
Jumpstart Securities does not maintain custody of customers’ funds or securities or effect public transactions on behalf of clients. In the event of an internal or external SBD,if telephone service is available, our registered persons will refer customer orders or instructions to the respective private placement issuer. The firm will make this information available to customers through its disclosure policy.
If SIPC determines that the firm is 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 customer accounts subject to SIPC regulation.
FINRA Rule 3510(a); Securities Exchange Act Rule 15c3-1; 15 U.S.C.
7. Data Back-Up and Recovery (Hard Copy and Electronic)
Our firm maintains its primary hard copy books and records and its electronic records at its main office in Atlanta, GA. Certain key records are backed up in real time via cloud technology (Sugar Sync), and via onsite external drives. In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our back-up 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, operations from our back-up site or an alternate location. If unable to locate customer account information we will physically mail customer update forms in order to retrieve customer data.
Rule: FINRA Rule 3510(c)(1).
8. Securities and Operational Assessments
A. Operational Risk
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 willdetermine the means of alternative communication, the communications options we will employ will include a Web site, secure e-mail, and/or numbers listed in Section I - Emergency Contact Information which will be forwarded to the appropriate cellularphone or back-up site. In addition, we will retrieve our key activity records as describedin the section above, Data Back-Up and Recovery (Hard Copy and Electronic).
Rules: FINRA Rules 3510(c)(3) & (f)(2).
B. Securities and Credit Risk
In the event of an SBD, we will determine the value and liquidity of our investments andother assets to evaluate our ability to continue to fund our operations and remain incapital compliance. We will contact our clearing firm, critical banks, and investors to apprise them of our Securities 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 contact SIPC or request assistance from our SRO.
Rules: FINRA Rules 3510(c)(3), (c)(8) & (f)(2)
9. Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry. We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of introducing investors to the issuers of private placement securities. The firm does not provide 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.
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. Resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption.
A. The Firms Mission Critical Systems
1. Order Taking: The firm does not receive orders from customers for public securities. During an SBD, either internal or external, we will continue to make introductions to the issuers of private placement through any methods that are available and reliable, and in addition, as communications permit, we will inform our customers when communications become available. Customers will be informed of alternatives by the telephone.
2. Order Entry: Currently, our does not transact or enter orders on behalf of clients In the event of an internal SBD, we will refer our customers to deal directly with the respective issuers that they were introduced to.
3. Mission Critical Systems Provided by Jumpstart Securities
Jumpstart Securities does not have a clearing relationship that provides order execution, order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.
Rules: FINRA Rules 3510(c) & (f)(1).
10. Alternate Communications Between the Firm and Customers, Employees, and Regulators
We now communicate with our customers using the telephone, e-mail, fax, 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 followup where a record is needed with paper copy in the U.S. mail.
Rule: FINRA Rule 3510(c)(4).
We now communicate with our employees using the telephone, e-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 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. Each designated principal of each employee shall be responsible for contacting the respective persons. Ultimately, Jervis Hough shall be responsible to make sure that each employee is contacted.
Rule: FINRA Rule 3510(c)(5).
We are currently members of the following SROs: FINRA, and SIPC. 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.
Rule: FINRA Rule 3510(c)(9).
11. Critical Business Constituents, Banks, and Counter-Parties
A. Business constituents
We have contacted 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 determined 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.
Rules: FINRA Rule 3510(c)(7).
The bank maintaining our account is: Bank of the Internet, and Pacific Mercantile Bank
Rules: FINRA Rule 3510(c)(7).
We have contacted our critical counter-parties, such as other broker-dealers or institutional customers, to determine if they would be able to carry out our transactions with them in light of the internal or external SBD. Where the transactions cannot becompleted, we will work with our counter-parties directly to make alternative arrangements to complete those transactions as soon as possible.
Rules: FINRA Rules 3510(a) & (c)(7).
12. Regulatory Reporting
Our firm is subject to regulation by: FINRA, SEC, and all states where the firm is registered. 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.
Rule: FINRA Rule 3510(c)(8).
13. Disclosure of Business Continuity Plan
We disclose in writing a summary of our BCP to customers when introductions are made to other firms, funds companies, and/ or money managers as well as annually and mail it to customers upon request. Our summary addresses the possibility of a future SBD and how we plan to respond to events of varying scope. In addressing the events of varying scope, our summary (1) provides specific scenarios of varying severity (e.g., a firm-only business disruption, a disruption to a single building, a disruption to a business district, a city-wide business disruption, and a regional disruption); (2) states whether we plan to continue business during that scenario and, if so, our planned recovery time; and (3) provides general information on our intended response. Our summary discloses the existence of back-up facilities and arrangements.
Rule: FINRA Rule 3510(e).
14. Updates and Annual Review
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, to modify it for any changes in our operations, structure, business, or location or those of our clearing firm.
Rule: FINRA Rule 3510(b).
15. Senior Manager Approval
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.
Rule: FINRA Rule 3510(d).
BCP Disclosure Statement
The firm has created a Business Continuity Plan (BCP) that provides for the firm to continue client service within a reasonable amount of time, given the scope and severity of a significant business disruption (SBD).
The BCP anticipates responding to both internal and external SBDs. An internal SBD, such as the loss of our telephone system, affects only the firm. The firm will respond to internal SBDs by re-routing calls to secondary numbers, and/or relocating its primary office to a secondary location, and/or, recovering data from a back-up storage media and/or a back-up site. The firm expects to recover froman internal SBD within one hour.
An external SBD, such as a power outage or flood, affects multiple businesses and can be local, regional, national, or global. The firm’s response to an external SBD relies more heavily on other organizations, such as the clearing firm and product sponsors. The firm expects to recover from an external SBD within six hours.
In the event a SBD prevents customers from contacting the firm by using the firm’s primary phone number, fax number, or email address, customers may contact the firm by using the following secondary contact information:
Secondary phone: (404) 388-9324
In the event of an internal or external SBD that causes the loss of our paper andhard copy records, we will attempt to physically recover them from our back-up files. If our primary site is inoperable, we will continue operations from our backup site or an alternate location. For the loss of electronic records, we will attempt to either physically recover the storage media or electronically recover data from our back-up files records management facility, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.
While no contingency plan can eliminate all risk of service interruption ortemporarily impeded account access, the firm continually assesses and updates itsBCP to mitigate all reasonable risk.
This disclosure is subject to modification.
Please contact us with any questions regarding this agreement by email email@example.com.