Business Continuity Plan Disclosure
As part of our effort to offer an ongoing contingency plan in the event of a Significant Business Disruption (SBD) ePLANNING Securities, Inc. has developed a Business Continuity Plan (BCP.) Significant Business Disruptions are disruptions that may occur internally or externally that would affect our firm’s ability to manage the day-to-day operation of our business and our ability to service our customers. SBD’s may vary in severity and the level of impact on our firm. Examples of a SBD include building fires, earthquakes and power outages. It is important that our customers are familiar with our company’s protocol for operation in the event of a SBD.
ePLANNING has incorporated a number of procedures allowing our firm to continue to operate and service our clients during a SBD. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm. ePLANNING provides our Business Continuity Plan Disclosure and our Trading Redundancy Procedures to our representatives and employees on an annual basis. It should be noted that during a SBD all clearing services, including trading and cashiering functions, would be handled directly though our clearing firm, National Financial Services, LLC. The representative would handle any "Away Held" business (i.e. mutual fund company, insurance company or custodian) through the third party vendor. When necessary ePLANNING may temporarily relocate internal operations to the nearest functioning branch office. In this case all branch offices will be notified by any means available of the temporary change in procedure and will be directed to follow the steps outlined in the BCP and Trading Redundancy procedures.
Our clearing firm, National Financial Services, LLC, has a fully functional backup facility to handle trading, sales and operational activity. In the event of a SBD National Financial Services, LLC will be able to facilitate all trading, and operational services at one of their four primary facilities. Each facility may operate as a backup site in the event of a SBD and each facility is physically located far enough apart from one another so that any disruption at one facility is unlikely to affect another.
ePLANNING does not maintain custody of customer’s funds or securities, rather all customer assets are maintained at our clearing firm, National Financial Services, LLC or other third party mutual fund and insurance companies. In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our clearing firm on their behalf, and if our web access is available, our firm will post on our web site that customers may access their funds and securities by contacting National Financial Services, LLC directly at 800-877-2410, prompts 2, 1. In addition, ePLANNING provides Trading Redundancy information to our clients and representatives on an annual basis with the Business Continuity Plan Disclosure. The information outlined in the Trading Redundancy Procedures provides contact information to reach National Financial Services, LLC directly in the event that clients and representatives are unable to reach the home office to transact on an account. For any business held away at a third party vendor (e.g. mutual fund and insurance companies) the client or representative may contact the company directly to transact on their account.
The BCP for ePLANNING addresses policies and procedures for data back up and recovery; mission critical systems; financial and operational systems; alternative means of communications with employees, customers and regulators; critical business constituents; and procedures for assuring our customers uninterrupted access to their account assets.
Our firm may communicate with our customers by telephone, e-mail, our Web site, fax, U.S. mail, and in person visits at our firm or at the customer’s location. In the event of an SBD we will determine the best course of action to use in effectively communicating with our representatives and customers. Examples include posting a notification with procedures to follow on our web site, sending out a mass distribution email and letter though the U.S Postal Service and recording a message on our home office outgoing voice message system. The method of communication will depend on the most effective and efficient means that is available to our firm for broadcasting a message to our representatives and customers.
The firm recognizes the potential for a Significant Business Disruption (SBD) and how critical it is to have a strategy for operating the broker/dealer during a SBD. The terms and conditions of our BCP are subject to change. ePLANNING will review and update our BCP on no less than an annual basis. Any updates to our BCP Disclosure will be provided to our customers and updated on our web site. Should you require a written copy of our BCP Disclosure or have any questions you may contact Scott Hultsman at (888) 815-1000 x155 or by email at
shultsman@eplanning.com.