BAC Florida Investments’ Business Continuity Plan Disclosure
BAC Florida Investments (“BFI”) has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.
BFI is an introducing broker/dealer and, as such, it relies on its correspondent clearing firm to perform certain functions on its behalf, including the execution of securities transactions and the maintenance of customer funds and securities. Accordingly, the Firm’s ability to respond to certain business disruptions is partially dependent on our clearing firm. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (305) 523-6510, you should go to our web site at http://bacinvestments.com. If you cannot access us through either of those means, you should contact our clearing firm, Pershing LLC, to process limited trade-related transactions, cash disbursements, and security transfers. Instructions to Pershing must be in writing and transmitted via facsimile or postal service as follows:
Pershing LLC
P.O. Box 2065
Jersey City, New Jersey 07303-2065
Fax: (201) 413-5368For additional information about how to request funds and securities when BFI cannot be contacted due to a significant business interruption, please visit the Pershing web site at http://www.pershing.com, click on “Business Continuity Disclosures,” and then on “Customer Support”or call (201) 413-3635 for recorded instructions. If you cannot access the instructions from the web site or previously noted telephone number, Pershing may be contacted at (213) 624-6100 extension 500 as an alternate telephone number for recorded instructions.
The specific transactions Pershing will perform for our clients, and the required accompanying information, are as follows:
A. Trades
Pershing will process the following closing security trades: (1) Sale of security position held long in your account or (2) Purchase of a security to close-out a short security position. These orders will only be handled as market orders.
In order to place these specific orders, you must provide Pershing with the following information:
1. Your brokerage account number;
2. Your name (as registered on the brokerage account);
3. Security description, including symbol or CUSIP® number;
and
4. Number of shares.B. Cash Disbursements
Pershing will process cash disbursements upon written instructions that must include the following information:
1. Your brokerage account number;
2. Your name (as registered on the brokerage account);
3. Exact amount to be disbursed;
4. Indicate method of disbursement (as follows) and provide
the information indicated:
a) Indicate method of disbursement (as follows) and
provide the information indicated:
b) For a check, which is payable to account name only,
indicate name and address of record check is to be
mailed to;
c) For federal funds, please indicate receiving bank name,
ABA number, and receiving bank account number. Please
note that the receiving bank account name and
brokerage account name must be identical unless we
have a letter of authorization on file indicating alternate
instructions.C. Securities Transfers
Pershing will process security transfer requests upon written instructions that must include the following information:
1. Your brokerage account number;
2. Your name (as registered on the brokerage account);
3. Description of security (ies) to be transferred, including
symbol(s) or CUSIP number(s);
4. Quantity to be transferred; and
5. Receiving account information for securities, as follows:
a) In order to transfer your account, to another
brokerage account at Pershing, please provide receiving
account number at Pershing (name and address on both
accounts must be the same);
b) In order to transfer your account to another financial
organization, please also provide the following
information:
• Name of the receiving financial organization;
• DTC number (if the receiving financial organization
is a registered broker-dealer);
• Account number at the receiving financial
organization.Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, Pershing LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four (4) hours. Your orders and requests for funds and securities could be delayed during this period.
Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within twelve (12) hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within three business days. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site http://www.bacinvestments.com or our firm emergency number (305) 310-2917 how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
For more information – If you have questions about our business continuity planning, you can contact us at (305) 523-6510.