Business Continuity Plan
The purpose of this disclosure is to provide you with very important information about the Independent Investment Bankers Corp. (“IIB”) Business Continuity Plan (“BCP”) so that you are aware of what you need to do to 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.
FINRA Rule 4370 requires members to establish emergency preparedness plans and procedures and requires each member to create and maintain a Business Continuity Plan and enumerates certain requirements that each plan must address. The Rule further requires members to update their BCPs 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 SBDs and how the member plans to respond to events of varying scope.
Emergency Contact Persons
The Firm’s two emergency contact persons are:
Dante Fichera Work (512) 266-3000
President Alt. (512) 266-9701
Alt. Email firstname.lastname@example.org
Houston Goddard Work (512) 266-3000
Chief Compliance Alt. (619) 890-6298
Officer (“CCO”) Email email@example.com
Alt. Email firstname.lastname@example.org
Dante Fichera is the President. Houston Goddard is the CCO.
It is the policy of Independent Investment Bankers, Corp.(“the firm”) to respond to a Significant Business Disruption (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. If an event occurs which causes us to suspend business operations, we will assure customers prompt access to funds and/or securities.
Significant Business Disruptions
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs only affect our firm’s ability to communicate and do business, such as a fire in the 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 the other organizations and systems, especially on third party vendors such as Bank of America, QuickBooks Online, Smarsh, Phone and Utility Companies.
Approval and Execution Authority
The President is the registered principal of the firm is responsible for approving the plan and for conducting the required annual review. The President has the authority to execute the Business Continuity Plan.
Plan Location and Access
The firm will maintain copies of its Business Continuity Plan and annual reviews along with any changes that have been made to it for inspection. An electronic copy of the plan is located on the company’s website so all employees may access it at any time.
The firm is a broker dealer that engages in private banking and private placements with sophisticated and institutional investors. The firm does not take possession of any bonds or stock, never holds positions for any clients and does not hold client funds.
The firm home office is located at 7035 Bee Caves Rd.,Suite 204, Austin, TX 78746. The mailing address is 2900 N. Quinlan Park Road, Suite 240-235, Austin, TX 78732. The main telephone number is (512) 266-3000.
Alternate Physical Locations of Employees
In the event of an external SBD, we will immediately evacuate our staff from the affected areas and follow all building procedures for a safe egress. Depending on the severity of the SBD, employees may be instructed to evacuate the area of Austin County. Safety of our employees is of paramount importance and will not be compromised.
The CCO will determine when/where employees should return to work. Together with the IT consultant they will work together to reestablish operations in a timely manner.
The firm maintains contact information for all employees on site as well as off site. Employees are required to inform the CCO whenever they change personal email/mobile phone numbers or any other contact information.
All mission critical employees have remote service capabilities and can access the company server to obtain data files. Files are also available offsite. All our other services are accessed via online services and personnel can access anywhere there is internet connection. In the event of the main office/Austin County evacuation all employees are required to log into their account via remote login services and alert their clients of the disruption or alternatively call them directly.
Customer Access to Funds and Securities
The firm does not hold any customer funds or securities. Customers can be assured that no matter what SBD occurs it will not result in any loss of customer funds or securities.
The firm is also a member of SIPC.
Data Back-Up and Recovery (Hard Copy and Electronic)
Our firm maintains its primary hard copy books and records at 7035 Bee Caves Rd.,Suite 204, Austin, TX 78746. The Company also maintains electronic company records offsite. The President is responsible for the maintenance of these books and records.
All accounting books and records are maintained with online QuickBooks and backed up to company server. Selected reconciliations and other supporting documents are maintained electronically on the Company server and backed up in the cloud utilizing box. The President is responsible for the maintenance of these books and records.
All email correspondence is backed up nightly and archived by Global Relay. A web-based email hosting service that our administrator is able to access 24 hours a day 7 days a week from any secured internet connection. Copies of CDs are sent by Global Relay to IIB and stored offsite.
The firm saves files to Egnyte throughout the day. The firm also backs up all files weekly to Company server. This is the responsibility of the President.
In the event of an internal or external SBD that causes the loss of our paper or electronic records we will physically recover them from our back-up site. Also all critical files are available remotely through redundant cloud services. If our primary site is inoperable, we will continue operations at a back-up facility to be determined by the President.
Financial and Operational Assessments
In the event of a SBD, the firm 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, some methods that we may employ are personal secure email, telephone, remote terminal access, and remote business email access. In addition we will quickly retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic)
In the event of a SBD, The President will evaluate our ability to continue to fund our operation and remain in capital compliance. Since the firm never takes possession of customer funds or securities, there is very little risk to the client/customers should our business be suspended or disrupted. In addition, we will contact our clients to apprise them of our financial status. The President and CCO, as principals and primary officers of the firm, have the financial means to personally fund operations should a short term SBD interrupt operations.
If the firm cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including infusing funds.
Mission Critical Systems
Our Firm’s mission critical systems are those which ensure prompt and accurate processing of securities transactions which includes proper documentation of due diligence files and offering documents. Other documentation will include engagement documents, correspondence, documentation of sophisticated investors and institutions, maintenance of customer invoices, and financial reporting responsibilities to FINRA.
If all methods of electronic communication are compromised, a decision will be made to continue business operations by the President. If possible, we will continue business over the phone with verbal and faxed confirmations of all pending requests.
The President will take special care in reviewing all transactions that occur during times of disruptions as our normal supervisory procedures become more difficult. However, compliance responsibilities will never cease to be a priority for the firm and all employees are held to the high standards of business ethics at all times.
The firm has taken steps to ensure that business lines will be able to be restored quickly with help from our technology partners and outside vendors, (as mentioned in section 7).
The specifics of a SBD can vary greatly and our response will be dependent on type and magnitude of the disruption. While it is impossible to predict all types of business disruptions, our lean size allows us to be very quick to respond and recover from such events.
The firm is a small broker-dealer with great potential for growth. As the company grows, new employees will be trained on the business continuity plan and how it affects their clients and responsibilities. The firm puts great importance on compliance and technology and therefore as we grow invest in infrastructure to replicate data and processes so that in the event of the SBD the downtown will be minimal.
Alternate Communications between the Firm, Employees, Vendors and Regulators
The firm utilizes many modes of communication with its employees and regulators including: phone, email, written, and personal meetings. In the event of an SBD, we will assess which means of communication is most effective for the given situation.
Person to evoke the use of the phone tree is Dante Fichera.
|Dante Fichera, President||The firm’s bank, accountants, Global Relay, Landlord, FINRA, Registered Representatives and any other critical vendors.|
In addition to the employee phone tree, the firm maintains a list of all phone numbers and email addresses for all its business partners and clients. A file is maintained on the server called “Critical Business Contacts”.
- Critical Business Constituents, Banks and Customer Contact
All vendors and critical business partners have been contacted regarding their ability to continue business operations during a SBD. The call tree mentioned in section 10 indicates who is responsible for reaching out to each vendor during the SBD.
The firm will continue to review the relationships with each business constituents to see that it fits our needs from disaster recovery stand point.
The firm uses Chase Bank and Bank of America as the primary business banking partners. There are locations around the United States of America should our local offices be unavailable due to a disaster or other SBD.
All customer contact information is maintained on the server and in the cloud. The President and CCO have the client contact lists off site as well, should they need to alert the clients of any SBD.
- Regulatory Reporting
Our Firm is subject to quarterly and annual FOCUS reporting to FINRA. We will report everything to FINRA electronically. Should we no longer be able to file electronically, we will submit paperwork via post or Federal Express in order to remain compliant.
The firm recognizes its reporting obligations do no halt because of a business disruption and will make every effort to maintain its stellar reporting reputation with FINRA.
- Disclosure of Business Continuity Plan
The firm provides its employees with access to the business continuity plan when they begin employment. The firm will also provide any client a copy of the business continuity plan upon their request.
- Updates and Annual Review
The firm will update this plan whenever we have a material change to our operations, business structure, business location, or any other issue involving business disruptions. In addition, the firm will review this BCP annually to modify it for any changes that may enhance our ability to diffuse, or mitigate any disruptions.
- Future Business Growth and Development
The firm is always looking for ways to develop and expand our business structure. As new lines of business are added (subject to FINRA approval) the Firm will continue to update and review the BCP to ensure that it continues to meet the needs of all business lines.
When a new employee (or team) joins the firm, part of the new hire process will include a review of the BCP to ensure all staff member are aware of their rolls and who to contact should the need arise.
Amendments will be made as necessary to our call tree and critical business contact list as needed.
Any addition of technology services that the new employee or team may need that is different from our current configuration will be incorporated into the BCP.