Pursuant to FINRA rule 4370 (formerly NASD Rule 3510), JMP Securities LLC, the broker-dealer subsidiary of JMP Group LLC, 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 JMP Securities’ BCP.
JMP Securities has provided for the off-site storage and backup of all its documents, data, email and instant messages. In addition, JMP Securities employs National Financial Services LLC as the clearing agent for its broker-dealer operation and thus benefits from the business continuity measures taken by National Financial Services. Because JMP Securities clears on a fully disclosed basis, all trading activities are processed and settled by National Financial Services, and all pertinent records are backed up by National Financial Services. What this means to our clients is that all electronic records pertaining to their accounts with JMP Securities are backed up by a network of secondary and, sometimes, tertiary business sites. In addition, should any of JMP Securities’ trading facilities become incapacitated, redundancies, alternate locations and third-party solutions have been established to provide ongoing service to clients.
Among other things, 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 JMP Securities 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, JMP Securities will have to depend upon its clearing agent.
JMP Securities generally caters to institutional clients who, by virtue of their business, hold their assets at an agent bank or prime broker other than JMP Securities. However, if a business disruption experienced by JMP Securities 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 to inquire about their holdings and/or place orders. For clients’ protection, National Financial Services will follow an identity verification protocol that may differ from the one observed by JMP Securities.
We intend to communicate with customers about the status of our disruptions through our website or by means of telephonic recordings.
Our BCP is reviewed periodically and is subject to modification without notice. If you have questions about our business continuity planning, please email us at firstname.lastname@example.org.