Business Continuity Disclosure Policy

First Clearing, LLC (“FCC”) acts as the clearing firm, providing back-office and trade support for the broker-dealer that you maintain an account with.  Your assets are maintained with FCC.  Accordingly, FCC is furnishing this document to you to provide information about our efforts to ensure that you are not significantly affected as a result of an emergency or significant business disruption.

Securities Industry regulations require each member firm to create and maintain a business continuity plan reasonably designed to meet its obligations to its clients or other counter-parties.  In accordance with these requirements, FCC has designed a business continuity plan to address possible scenarios in efforts to minimize and service impact to our introducing firms or their clients.

In keeping with the regulatory requirements, the business continuity plan for FCC is designed to address key areas of concern – including but not limited to the following:

    •     Data back-up and recovery;
    •     All mission critical systems;
    •     Financial and operational assessments;
    •     Alternate means of communication between FCC and its customers;
    •     Alternate means of communication between FCC and its employees;
    •     Alternate physical locations of employees;
    •     Critical business constituent, bank and counter-party impact;
    •     Regulatory reporting;
    •     Communications with regulators; and
    •     How FCC will ensure that customers have access to their funds and securities   
       in the event FCC determines it is unable to continue its business.

Since events creating business disruptions may vary in nature and scope, FCC has anticipated scenarios in which the following are affected:

    •     A primary FCC building at its headquarter location
    •     An FCC branch location
    •     A city wide area
    •     A regional area

Regardless of the scope of potential disruption, FCC intends to continue to provide service to its introducing firms and their clients.

In the event where a primary building or business district is affected, the firm is fortunate to have a divided corporate presence in its headquarters area, with two primary buildings located approximately twenty miles apart.  Both buildings are served by UPS systems and have 24-hour security services.  Should one of the primary buildings be affected by a disruption, the other building can be used to help restore operations.
In the unlikely event of a citywide or regional disruption, FCC has established a recovery site approximately 150 miles from its headquarters that can be used to restore time sensitive functions as soon as key employees are relocated to the facility.  Additionally, as a subsidiary of a large financial institution, FCC would intend to take advantage of any available facilities of other affiliates that may be located in other geographical regions.  In the event that any such disruption occurs, we have developed alternative service arrangements, systems, locations and contingency plans to ensure that any service is quickly restored.

At a minimum, the FCC business continuity plan is reviewed, updated and tested on an annual basis.  Additionally, our primary internal and external application providers periodically conduct testing of their own back-up capabilities to ensure that, in the event of an emergency or significant business disruption, they will be able to provide us with the critical information and applications we need to continue or promptly resume our business.

Making sure that any type of disruption does not unduly impact our introducing firms or their clients is extremely important to us, and our business continuity plan is designed to allow us to continue to provide the quality service you have come to expect from FCC.