Continuity Plan Disclosure
Business Continuity Plan Regulation
Under Rule 3510 adopted by the Financial Industry Regulatory Authority (FINRA), member firms are required to maintain a current Business Continuity Plan (BCP) that addresses the potential for events to occur that could affect the firm’s ability to conduct business as usual. Under the Rule, CU Capital Market Solutions is responsible for ensuring the accuracy, completeness and adaptability of its BCP in regards to the size, complexity and nature of the firm.
This document shall serve as a disclosure notice to clients in regards to CMS’ BCP. Due to this document’s purpose and the overall nature of BCPs, CMS’ BCP and all associated documents are subject to modification and serve only as a guide by which CMS will attempt to resume its operations in the event of a disruption to the firm’s ability to operate. The most current version of this document will be available at www.cucapitalmarketsolutions.com or by requesting a written copy by mail.
CMS’ policy is 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 clients to transact business. In the event that we determine we are unable to continue our business, we will make every effort to advise clients promptly. CMS does not hold client funds or securities, so CMS’ BCP and response to an SBD do not include procedures to ensure that clients’ access to their funds or securities is not disrupted.
Back-up Facilities and Arrangements
CMS maintains access to a back-up site that offers the infrastructure necessary to establish operations in the event that CMS’ primary facility is unavailable. In the unlikely event that both the primary facility and the back-up site are rendered inaccessible, CMS will take all reasonable measures to secure additional facilities and associated infrastructure. CMS has established relationships with several third parties to ensure that every reasonable effort can be made to successfully re-establish operations in a timely manner following an SBD. It should also be noted that the response to any SBD will be dictated by the features of the SBD itself and that a major component of any recovery effort will be the decisions made by CMS’ available staff.
In the event that a localized SBD (building fire, tornado, burst pipe, etc.) or a citywide or regional SBD (power outage, significant weather event, chemical exposure, etc.) affects CMS’ primary facilities, CMS will relocate all available staff and assets to its back-up site and resume operations as promptly as possible.
In the event CMS’ ability to conduct business is limited because of an SBD’s effects on the market or other firms, CMS will continue appropriate operations at its primary facility. Once normal market access is restored, all operations will return to their normal states.
Recognizing that it is impossible to plan for every possible SBD, CMS has made a concentrated effort to ensure that its BCP addresses the most likely SBD scenarios and that the BCP is flexible enough to be useful in any situation. In all foreseeable SBD scenarios, CMS intends to re-establish basic operations within 24 hours of invoking the BCP.