Pursuant to FINRA rule 4370 (formerly NASD Rule 3510), Citizens JMP Securities, LLC (“Citizens JMP”) has developed a business continuity plan, or BCP, as part of its ongoing efforts to prevent or mitigate the impact of business interruptions. The following is a summary of Citizens JMP’s BCP.
Citizens JMP has provided for the off-site storage and backup of all its documents, data, email and instant messages. In addition, Citizens JMP employs National Financial Services LLC and Mirae Asset Securities as the clearing agents for its broker-dealer operation and thus benefits from the business continuity measures taken by National Financial Services and Mirae Asset Securities. Because Citizens JMP clears on a fully disclosed basis, all trading activities are processed and settled by National Financial Services and Mirae Asset Securities, and all pertinent records are backed up by National Financial Services and Mirae Asset Securities. All electronic records pertaining to customer accounts with Citizens JMP are backed up by a network of secondary and, sometimes, tertiary business sites. Should any of Citizens JMP’s trading facilities become incapacitated, redundancies and third-party solutions have been established to provide ongoing service to clients.
Our business continuity plan addresses: data backup and recovery; mission critical systems; financial and operational assessments; alternative communications with customers, employees and regulators; alternate physical locations of employees; critical supplier, contractor, bank and counter-party impacts; regulatory reporting; and customer assurance of prompt access to funds and securities if Citizens JMP becomes unable to continue its business. In addition, our BCP addresses tolerance levels for resumption of various services and recovery from various potential disruptions, underpinned by the necessity of maintaining functioning or resuming functioning at the quickest possible rate. Depending upon the severity of a disruption, our BCP could enable the resumption of business within minutes or hours. In more severe cases, Citizens JMP will have to depend upon its clearing agent.
Citizens JMP generally caters to institutional clients who, by virtue of their business, hold their assets at an agent bank or prime broker other than Citizens JMP. However, if a business disruption experienced by Citizens JMP is so severe that it prevents us from remaining in business, we will assure our customers’ prompt access to any funds and securities custodied by our clearing agent. In such a catastrophic event, clients are directed to call National Financial Services at (800) 801-9942 or Mirae Asset Securities at (212) 407-1000 to inquire about their holdings and/or place orders. For clients’ protection, National Financial Services and Mirae Asset Securities will follow and identity verification protocol that may differ from the one observed by Citizens JMP.
We intend to communicate with customers about the status of our disruptions through email, phone, or our website.
Our BCP is reviewed at least annually and is subject to modification without notice. If you have questions about our business continuity planning, please email us at firstname.lastname@example.org.