FINRA Rule 4370 requires members and member organizations to develop and maintain a written business continuity and contingency plan (BCP) and to establish procedures relating to an emergency or significant business disruption. Such procedures must be reasonably designed to enable members and member organizations to meet their existing obligations to customers. In addition, such procedures must address their existing relationships with other broker-dealers, and counter-parties. Furthermore, each member or member organization must disclose to its customers how its business continuity and contingency plan addresses the possibility of a future significant business disruption and how the member or member organization plans to respond to events of varying scope. At a minimum, such disclosure must be made in writing to customers at account opening, posted on the Internet Web site of the member or member organization and mailed to customers upon request.
SIG Brokerage (SB LP) has established a BCP which envisions several potential business disrupting scenarios: 1) events that are specific to SB LP; 2) events that disrupt the NYSE trading floor; 3) events that disrupt SB LP's clearing firm. In each scenario SB LP will implement plans designed to restore critical systems and SB LP anticipates being functional within 24 hours. In the event of scenario 2, recovery is largely beyond the control of SB LP and steps for recovery depend upon the NYSE itself. SB LP for its part has contacted the NYSE and arranged to participate in its back-up facilities. In the event of scenario 3, it depends upon the level of disruption; SB LP will coordinate with its clearing firm, which also has its own BCP
SB LP will update the BCP as needed and any material changes will be available on our Web site. If you have further questions regarding our BCP please contact your SIG Brokerage representative.