paulson investment company, inc...paulson investment company, llc business continuity plan (5/14/18)...

Paulson Investment Company, LLC Business Continuity Plan (5/14/18)

Paulson Investment Company, LLC Business Continuity Plan (“BCP”)

I. Emergency Contact Person

Our firm’s two emergency contact persons are: Starla Goff, Chief Executive Officer Telephone: (503) 248-2393 (work); (503) 504-1519 (mobile) Email: [email protected] Basil Christakos, Chief Compliance Officer Telephone: (646) 553-3684 (work); (201) 456-1662 (mobile) Email: [email protected]

These names will be updated in the event of a material change, and our Executive Representative will review them within 17 days of the end of each calendar year.

Rule: FINRA Rule 4370

II. Firm Policy This policy should be given to all employees and independent contractors. Our firm’s 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 the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities. A. Significant Business Disruptions (“SBDs”) Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm. B. Approval and Execution Authority Starla Goff, CEO, a registered principal, is responsible for approving the plan and for conducting the required annual review. Starla Goff, CEO has the authority to execute this BCP.

mailto:[email protected]



C. Plan Location and Access Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. We have given FINRA District Office 8 a copy of our plan. An electronic copy of our plan is located in the Firm’s Office 365 Sharepoint environment in the Compliance shared folder and in our e-mail server archived by Smarsh Inc. III. Business Description Our firm conducts business in equity, fixed income, derivative securities, and investment banking. Our firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept, enter and execute orders. All transactions are sent to our clearing firm, which compares them, allocates them, clears and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services retail and institutional customers. Our clearing firm is: RBC Correspondent Services 60 South 6th Street – P18 Minneapolis, MN 55402 Phone: (612) 607-8903 Web Site: http://www.rbccorrespondentservices.com Our contact person at that clearing firm is: Mark Rohlik RBC Correspondent Services 60 South 6th Street – P18 Minneapolis, MN 55402 E-mail: [email protected] Our clearing firm has given us a group number to use in the event that the contact person listed above is not available. That number is: (612) 371-2862. IV. Office Locations Our firm has offices in the following locations:

1. Office Location Lake Oswego, Oregon Lake Oswego Office 5335 Meadows Road, Suite 465 Lake Oswego, OR 97035



(503) 243-6000 Our employees may travel to that office by means of foot, car, train, bus or taxi. We engage in order taking and entry at this location 2. Office Location New York City, New York

New York Office 40 Wall Street 23rd Floor New York, New York 10005

(646) 553-3670 Our employees may travel to that office by means of foot, car, train, bus or taxi. We engage in order taking and entry at this location 3. Office Location Walnut Creek, CA

San Francisco Office 1255 Treat Blvd., #300 Walnut Creek, CA 94597 (415) 761-2082 Our employees may travel to that office by means of foot, car, train, bus or taxi. We engage in order taking and entry at this location 4. Office Location Chicago, IL Chicago Office 2141 West North Ave., 2nd Floor Chicago, IL 60647 (312) 940-8321 Our employees may travel to that office by means of foot, car, train, bus or taxi. 5. Office Location Coeur d’Alene, ID

Coeur d’Alene Office 421 Sherman Avenue, #203 Coeur d’Alene, ID 83814 (208) 415-1932

Our employees may travel to that office by means of foot, car, train, bus or taxi. We engage in order taking and entry at this location


6. Office Location Memphis, TN 1661 International Drive, Suite 400 Memphis, TN 38120 (901) 827-3481


7. Office Location Tampa, FL

Tampa Office 4905 West Laurel Street, Suite 101 Tampa, FL 33607 (813) 369-5448

Our employees may travel to that office by means of foot, car, train, bus or taxi. We engage in order taking and entry at this location 8. Office Location Hazlet, NJ

Talent Technology Center 12 Crown Plaza, Suite 201 Hazlet, New Jersey 07730



V. Alternative Physical Location(s) of Employees In the event of an SBD, our staff will operate electronically away from affected offices. Through our clearing firm platform and technology solutions, our staff can process transactions electronically including execution of customer orders and instructions regarding the transmission of funds to and from our clearing firm. Rule: FINRA Rule 4370(c)(6) VI. Customers’ Access to Funds and Securities Our firm does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm, RBC Correspondent Services. 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 us at 855-653-3444, by going to our web site at http://www.paulsoninvestment.com or by emailing us [email protected]. The firm will make this information available to customers through its disclosure policy. If SIPC determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books and records identifying customer accounts subject to SIPC regulation. Rules: FINRA Rule 4370(a); Securities Exchange Act Rule 15c3-1: 15 U.S.C. 78eee (2003) VII. Data Back-Up and Recovery (Hard Copy and Electronic) To the extent the firm maintains hard copy books and records, those records are stored in the following two locations:

Chicago Office 2141 West North Avenue Second Floor Chicago, IL 60647

Alex Winks, the firm’s Chief Financial Officer and Chief Operating Officer, is responsible for the maintenance of these books and records.

Lake Oswego Office 5335 Meadows Road Suite 465 Lake Oswego, OR 97035

http://www.paulsoninvestment.com/


Dane Grouell, one of the firm’s Compliance officers, is responsible for the maintenance of these books and records. The majority of the firm’s records are stored and maintained in electronic format. These electronic documents are stored in multiple cloud environments. As such, in the event of an SBD, the firm will be able to access these records remotely. Our firm maintains the following document types and forms which may be transmitted to our clearing firm, but are not required to be transmitted to our clearing firm: New Account Forms Trust Agreements Articles of Conversion Rule: FINRA Rule 4370(c)(1) VIII. Financial and Operational Assessments

A. Operational Risk Operational risk includes the firm’s ability to maintain communications with customers and to retrieve key activity records through its mission critical systems. In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter-parties, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our web site, telephone voice mail, secure e-mail, etc. In addition, our key activity records will be available on the hosted cloud environments as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic). Rules: FINRA Rules 4370(c)(3) & 4370(f)(2) B. Financial and Credit Risk In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. We will contact our clearing firm, critical banks, and investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including the protection of customer assets, and the closing of our operations. Rules: FINRA Rules 4370(c)(3), 4370(c)(8) & 4370(f)(2)


IX. Mission Critical Systems Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, and entry of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking and entry. Our clearing firm provides, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. Our clearing firm contract provides that our clearing firm will maintain a business continuity plan and the capacity to execute that plan. Our clearing firm represents that it will advise us of any material changes to its plan that might affect our ability to maintain our business and presented us with an executive summary of its plan, which is attached. In the event our clearing firm executes its plan, it represents that it will notify us of such execution and provides us equal access to services as its other customers. If we reasonably determine that our clearing firm has not or cannot put its plan in place quickly enough to meet our needs, or is otherwise unable to provide access to such services, our clearing firm represents that it will assist us in seeking services from an alternative source. Our clearing firm represents each primary computer center has a corresponding back-up/disaster recovery site. Our clearing firm represents that it operates a back-up operating facility in a geographically separate area with the capability to conduct the same volume of business as its primary site. Our clearing firm has also confirmed the effectiveness of its back-up arrangements to recover from a wide scale disruption by testing, and it has confirmed that it tests its back-up arrangements four times a year. Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure – particularly telecommunications – can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption. Our clearing firm has the following SBD recovery time and resumption objectives: recovery time period of less than four hours; and resumption time of less than four hours.

A. Our Firm’s Mission Critical Systems

1. Order Taking Currently, our firm receives orders from customers via telephone, by in-person visits by the customer or by direct entry into the PennTrade portal. During an SBD, either internal or


external, we will continue to take orders through any of these methods that are available and reliable, and in addition, as communications permit, we will inform our customers when communications become available to tell them what alternatives they have to send their orders to us. Customers will be informed of alternatives by voice messages and by postings on our web site. If necessary, we will advise our customers to place orders directly with us by calling (503) 243-6000.

2. Order Entry Currently, our firm enters orders by recording them on paper and electronically and sending them to our clearing firm electronically or telephonically, through their BetaLink order entry system. Alternatively, we place customer orders through FlexTrade. FlexTrade has provided its Business Continuity Plan, which includes contingency plans in the event of significant business disruptions. In the event of an internal SBD, we will enter and send records to our clearing firm by the fastest alternative means available, which include e-mail, US Mail, Overnight Courier, and facsimile. In the event of an external SBD, we will maintain the order in electronic or paper format, and deliver the order to the clearing firm by the fastest means available when it resumes operations. In addition, during an internal SBD, we may need to refer our customers to deal directly with our clearing firm for order entry.

3. Order Execution In the event of an internal SBD, we would release all orders to RBC Correspondent Services for execution. In the event of an external SBD, we would release all orders to RBC Correspondent Services for execution.

4. Other Services Currently Provided to Customers We currently do not supply any other mission critical services to customers. Rules: FINRA Rules 4370(c) & 4370(f)(1) X. Alternate Communications between the Firm and Customers,

Employees, and Regulators A. Customers We now communicate with our customers using the telephone, e-mail, our web site, facsimile, US mail, and in person visits. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by e-mail but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in US mail.


Rule: FINRA Rule 4370(c)(4)

B. Employees and Affiliates We now communicate with our employees and affiliates using the telephone, e-mail, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers. The person to invoke use of the call tree is: Starla Goff, CEO Caller Call Recipients Starla Goff Basil Christakos, Dane Grouell, Alex Winks Sales Department Personnel, Branch Offices Trading Department Personnel Syndicate Department Personnel Operations Department Personnel IT Department Personnel Accounting Department Personnel Investment Banking Personnel Rule: FINRA Rule 4370(c)(5)

C. Regulators We are currently members of FINRA. We communicate with our regulator using the telephone, e-mail, facsimile, US mail, and in person. In the event of an SBD, we will assess which means of communication are still available to us, and us the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. Rule: FINRA Rule 4370(c)(9) XI. Critical Business Constituents, Banks, and Counter-Parties

A. Business Constituents We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm.


Rule: FINRA Rule 4370(c)(7)

B. Banks We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of the internal or external SBD. The bank maintaining our operating account is: First Republic Bank Attn: Janina Pulido 111 Pine St., Ninth Floor San Francisco, CA 94111 (415) 288-7503 If our banks and other lenders are unable to provide the financing, we will seek alternative financing immediately from alternative sources. Rule: FINRA Rule 4370(c)(7)

C. Counter-Parties We have contacted our critical counter-parties, such as other broker-dealers or institutional customers, to determine if we will be able to carry out our transactions with them in light of the internal or external SBD. Where the transactions cannot be completed, we will work with our clearing firm or contact those counter-parties directly to make alternative arrangements to complete those transactions as soon as possible. Rules: FINRA Rules 4370(a) & 4370(c)(7) XII. Regulatory Reporting Our firm is subject to regulations by: SEC, FINRA, and all fifty states. We now file reports with our regulators using paper copies in US mail, and electronically using facsimile, e-mail, and the Internet. In the event of an SBD, we will check with the SEC, FINRA, and other regulators to determine which means of filing are still available to us, and us the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.


Our Regulator contact information is:

1. Financial Industry Regulatory Authority (FINRA)

FINRA District 8 Ron Sellers Principal Regulatory Coordinator - FINRA 55 West Monroe, Suite 2700 Chicago, IL 60603-5001 Tell: (312) 899-4680 Fax: (312) 606-0742 [email protected] Main Office Tell: (312) 899-4400 2. Securities & Exchange Commission

U.S. Securities and Exchange Commission Chicago Regional Office David Glockner, Regional Director 175 West Jackson Boulevard, Suite 900 Chicago, IL 60604 Phone: 312-353-7390 E-mail: [email protected]

3. Alabama

Securities Commission Joseph P. Borg, Director 401 Adams Avenue, Suite 280 Montgomery, AL 36130-4700 Phone: (334) 242-2984 Fax: (334) 242-0240 P.O. Box 304700 Montgomery, AL 36130-4700 4. Alaska

Department of Commerce, Community and Economic Development Division of Banking and Securities Kristy Naylor, Acting Director 150 Third Street, Room 217 P.O. Box 110807 Juneau, AK 99811-0807 Phone: (907) 465-2521 Fax: (907) 465-2549




5. Arizona

Corporation Commission Securities Division Matthew J. Neubert, Director 1300 West Washington Street, Third Floor Phoenix, AZ 85007 Phone: (602) 542-4242 Fax: (602) 388-1335

6. Arkansas

Securities Department Edmond Waters, Securities Commissioner 201 East Markham, Room 300 Little Rock, AR 72201-1692 Phone: (501) 324-9260 Fax: (501) 324-9268

7. California

Department of Business Oversight Jan Lynn Owen, Commissioner 1515 K Street, Suite 200 Sacramento, CA 95814-4052 Phone: (866) 275-2677 Fax: (916) 322-1559 8. Colorado

Division of Securities Gerald Rome, Securities Commissioner 1560 Broadway, Suite 900 Denver, CO 80202 Phone: (303) 894-2320 Fax: (303) 861-2126

9. Connecticut

Department of Banking Lynn McKenna-Krumins, Director of Securities 260 Constitution Plaza Hartford, CT 06103-1800 Phone: (860) 240-8230


Fax: (860) 240-8295 10. Delaware

Department of Justice Investor Protection Unit Gregory Strong, Investor Protection Director Carvel State Office Building 820 North French Street, Fifth Floor Wilmington, DE 19801 Phone: (302) 577-8424 Fax: (302) 577-6987

11. District of Columbia

Department of Insurance, Securities and Banking Securities Bureau Theodore A. Miles, Associate Commissioner, Securities 810 First Street, NE, Suite 701 Washington, DC 20002 Phone: (202) 442-7800 Fax: (202) 354-1092 12. Florida

Office of Financial Regulation Lee Kell, Director, Division of Securities 200 East Gaines Street Tallahassee, FL 32399-0372 Phone: (850) 410-9500 Fax: (850) 410-9748

13. Georgia

Office of the Secretary of State Division of Securities Noula Zaharis, Securities Division Director Two Martin Luther King, Jr. Drive SE 802 West Tower Atlanta, GA 30334 Phone: (404) 654-6023 Fax: (404) 657-8410


14. Hawaii

Department of Commerce & Consumer Affairs Division of Business Regulation Ty Nohara, Commissioner of Securities 335 Merchant Street, Room 203 Honolulu, HI 96813 Phone: (808) 586-2744 Fax: (808) 586-2733

15. Idaho

Department of Finance Jim Burns, Securities Bureau Chief 800 Park Boulevard, Suite 200 Boise, ID 83712 Phone: (208) 332-8004 Fax: (208) 332-8099 16. Illinois

Office of the Secretary of State Securities Department Tanya Solov, Director of Securities 69 West Washington Street, Suite 1220 Chicago, IL 60602 Phone: (312) 793-3384 Fax: (312) 793-1202

17. Indiana

Office of the Secretary of State Securities Division Alex Glass, Securities Commissioner 302 West Washington, Room E-111 Indianapolis, IN 46204 Phone: (317) 232-6681 Fax: (317) 233-3675

18. Iowa

Insurance Division Securities Bureau Craig Goettsch, Securities Administrator 601 Locust, 4th Floor


Des Moines, IA 50309 Phone: (515) 281-5705 Fax: (515) 281-3059

19. Kansas

Office of the Securities Commissioner John R. Wine, Jr., Securities Commissioner 109 SW 9th Street, Suite 600 Topeka, KS 66612 Phone: (785) 296-3307 Fax: (785) 296-6872 20. Kentucky

Department of Financial Institutions Shonita Bossier, Director, Division of Securities 1025 Capital Center Drive, Suite 200 Frankfort, KY 40601 Phone: (502) 573-3390 Fax: (502) 573-2182

21. Louisiana

Securities Commission Office of Financial Institutions Len Riviere, Deputy Commissioner of Securities 8660 United Plaza Blvd., Second Floor Baton Rouge, LA 70809-7024 Phone: (225) 925-4512

22 Maine

Department of Professional & Financial Regulation Judith M. Shaw, Securities Administrator 121 State House Station Augusta, ME 04333-0121 Phone: (207) 624-8551 Fax: (207) 624-8590

23. Maryland

Office of the Attorney General Division of Securities Melanie Senter Lubin, Securities Commissioner 200 Saint Paul Place


Baltimore, MD 21202-2020 Phone: (410) 576-6360 Fax: (410) 576-6532 24. Massachusetts

Securities Division Bryan Lantagne, Director One Ashburton Place, Room 1701 Boston, MA 02108 Phone: (617) 727-3548 Fax: (617) 248-0177

25. Michigan

Department of Licensing and Regulatory Affairs Corporation Securities and Commercial Licensing Bureau Julia Dale, ActingBureau Director 2501 Woodlake Circle Okemos, MI 48864 PO 30018 Lansing, MI 48909 Phone: (517) 241-9202 Fax: (517) 241-3356

26. Minnesota

Department of Commerce Jessica Looman, Commissioner 85 East 7th Place, Suite 280 Saint Paul, MN 55101 Phone: (651) 539-1638 Fax: (651) 296-4328

27. Mississippi

Office of the Secretary of State Securities Division Jessica Long, Asst. Secretary of State 125 South Congress Street PO Box 136 Jackson, MS 39201 Phone: (601) 359-1334 Fax: (601) 359-9070


28. Missouri

Office of the Secretary of State David Minnick, Commissioner 600 West Main Street Jefferson City, MO 65101 Phone: (573) 751-4136 Fax: (573) 526-3124 29. Montana

Commissioner of Securities & Insurance Montana State Auditor’s Office Lynne Egan, Deputy Securities Commissioner 840 Helena Avenue Helena, MT 59601 Phone: (406) 444-2040 Fax: (406) 444-5558

30. Nebraska

Nebraska Department of Banking & Finance Bureau of Securities Claire McHenry, Deputy Director – Securities Bureau 1526 K St. Suite 300 Lincoln, NE 68508 Phone: (402) 471-3445

31. Nevada

Secretary of State Securities Division Diana Foley, Securities Administrator 555 East Washington Avenue, Suite 5200 Las Vegas, NV 89101 Phone: (702) 486-2440 Fax: (702) 486-2452

32. New Hampshire

Bureau of Securities Regulation Department of State Barry Glennon, Director of Securities Regulation 107 North Main Street, #204 Concord, NH 03301-4989


Phone: (603) 271-1463 Fax: (603) 271-7933 33. New Jersey

Department of Law & Public Safety Bureau of Securities Christopher Gerold, Bureau Chief 153 Halsey Street, 6th Floor Newark, NJ 07102 Phone: (973) 504-3600 Fax: (973) 504-3601

34. New Mexico

Regulation & Licensing Department Securities Division Ben Schrope, Acting Director of Securities 2550 Cerrillos Road Santa Fe, NM 87505 Phone: (505) 476-4580 Fax: (505) 984-0617

35. New York

Office of the Attorney General Investor Protection Bureau Katherine C. Milgram, Bureau Chief 28 Liberty Street New York, NY 10005 Phone: (212) 416-8222 Fax: (212) 416-8816 36. North Carolina

Department of the Secretary of State Securities Division Kevin Harrington, Deputy Securities Administrator 2 S. Salisbury Street Raleigh, NC 27601 Phone: (919) 733-3924 Fax: (919) 807-2183

37. North Dakota

Securities Commission


Karen Tyler, Commissioner 600 East Boulevard State Capital, 5th Floor Bismarck, ND 58505-0510 Phone: (701) 328-2910 Fax: (701) 328-2946 38. Ohio

Division of Securities Andrea Seidt, Commissioner 77 South High Street, 22nd Floor Columbus, OH 43215-6131 Phone: (614) 644-7381 Fax: (614) 466-3316

39. Oklahoma

Securities Commissioner Irving Faught, Administrator 204 N. Robinson, Suite 400 Oklahoma City, OK 73102-7001 Phone: (405) 280-7700 Fax: (405) 280-7742 40. Oregon

Department of Consumer & Business Services Division of Finance & Corp. Securities JP Jones, Division Administrator 350 Winter Street, NE Room 410 Salem, OR 97301-3881 Phone: (503) 378-4140 Fax: (503) 947-7862

41. Pennsylvania

Pennsylvania Department of Banking and Securities Robin Wiessmann, Commission (Vice Chair) and Secretary of Banking and Securities Eastgate Office Building 17 North 2nd Street, Suite 1300 Harrisburg, PA 17101-2290 Phone: (717) 787-2665 Fax: (717) 783-5125


42. Puerto Rico

Commissioner of Financial Institutions Damaris Mendoza-Roman, Securities Administrator Fernandez Juncos Station P.O. Box 11855 San Juan, PR 00910-3855 Phone: (787) 723-3131 Fax: (787) 723-4225

43. Rhode Island

Department of Business Regulation Maria D’Alessandro, Deputy Director of Securities, Commercial Licensing and Gaming and Athletics Division 1511 Pontiac Avenue John O. Pastore Complex Bldg. 69-1 Cranston, RI 02920-4407 Phone: (401) 462-9527 Fax: (401) 462-9645 44. South Carolina

Office of the Attorney General Securities Division T. Stephen Lynch, Deputy Securities Commissioner Rembert C. Dennis Office Building, Suite 501 1000 Assembly Street PO Box 11549 Columbia, SC 29211-1549 Phone: (803) 734-9916 Fax: (803) 734-3677

45. South Dakota

Department of Labor and Relations Division of Insurance Securities Regulation Larry Deiter, Director 124 South Euclid St., Suite 104 Pierre, SD 57501-3185 Phone: (605) 773-4823 Fax: (605) 773-5953


46. Tennessee

Department of Commerce & Insurance Securities Division Frank Borger-Gilligan, Assistant Commissioner for Securities Day Crockett Tower, Suite 680 500 James Robertson Parkway Nashville, TN 37243-0575 Phone: (615) 741-2947 Fax: (615) 532-8375 47. Texas

State Securities Board Travis Iles, Securities Commissioner 208 East 10th Street, 5th Floor PO Box 13167 Austin, TX 78701 Phone: (512) 305-8300 Fax: (512) 305-8310 48. U.S. Virgin Islands Division of Banking and Insurance Deverita Sturdivant, Chief of Securities Regulation 18 Kongens Gade Saint Thomas, VI 00802 Phone: (340) 774-7166 49. Utah

Department of Commerce Division of Securities Thomas Brady, Director 160 East 300 South, 2nd Floor PO Box 146760 Salt Lake City, UT 84111-6760 Phone: (801) 530-6600 Fax: (801) 530-6980

50. Vermont

Department of Financial Regulations Michael Pieciak, Commissioner 89 Main Street, 3rd Floor


Montpelier, VT 05620-3101 Phone: (802) 828-3420 Fax: (802) 828-2896

51. Virginia

State Corporation Commission Division of Securities & Retail Franchising Ronald W. Thomas, Director 1300 East Main Street, 9th Floor PO Box 1197 Richmond, VA 23218 Phone: (804) 371-9051 Fax: (804) 371-9911

52. Washington

Department of Financial Institutions Securities Division William Beatty, Director of Securities 150 Israel Road, SW PO Box 9033 Tumwater, WA 98507-9033 Phone: (360) 902-8760 Fax: (360) 902-0524 53. West Virginia

Office of the State Auditor Securities Division Lisa Hopkins, Senior Deputy Commissioner of Securities Building 1 Room W-100 Charleston, WV 25305-0230 Phone: (304) 558-2257 Fax: (304) 558-4211

54. Wisconsin

Department of Financial Institutions Division of Securities Leslie Van Buskirk, Administrator 201 W. Washington Avenue, Suite 300 PO Box 1768 Madison, WI 53701-1768 Phone: (608) 266-1064 Fax: (608) 264-7979


55. Wyoming

Secretary of State Compliance Division Kelly Janes, Division Director 2020 Carey Avenue, Suite 700 Cheyenne, WY 82002 Phone: (307) 777-7370 Fax: (307) 777-7640

Rule: FINRA Rule 4370(c)(8) XIII. Disclosure of Business Continuity Plan We disclose in writing a summary or our BCP to customers at account opening, and annually. We also post the summary on our web site and will mail it to customers upon request. Our summary addresses the possibility of a future SBD and how we plan to respond to events of varying scope. In addressing the events of varying scope, our summary (1) provides specific scenarios of varying severity (e.g., a firm-only business disruption, a disruption to a single building, a disruption to a business district, a city-wide business disruption, and a regional disruption); (2) states whether we plan to continue business during that scenario and, if so, our planned recovery time; and (3) provides general information on our intended response. Our summary discloses the existence of back-up facilities and arrangements. Rule: FINRA Rule 4370(e) XIV. Updates and Annual Review The firm’s Chief Executive Officer or his/her designee will update and approve this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our Chief Compliance Officer or his designee will review and approve this BCP annually, in the last 2 months of each year, to modify it for any changes in our operations, structure, business, or location or those of our clearing firm. Rule: FINRA Rule 4370(b)


XV. Senior Manager Approval I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD. Rule: FINRA Rule 4370(d)

Business continuity plan

As part of this commitment, and in compliance with internal policies and industry regulations, the Firm has developed and implemented Business Continuity Plans (the “Plans”) for its business units. Each Plan is developed by identifying each business unit’s critical risks and documenting the functional requirements needed to reestablish essential business operations. The Plans document the actions and procedures to be followed before, during, and after a prolonged service outage resulting from the loss of operational facilities, critical information systems, or essential personnel. In instances by which business processes require recovery from a significant operational disruption, the Plans include off-site recovery environments, work-area displacement agreements, and/ or work-from-home arrangements.

The Firm conducts annual disaster recovery exercises, designed to ensure computing systems and networks are built with sufficient redundancies. The Firm also requires all business units conduct an annual contact exercise to

ensure personnel, particularly recovery team personnel and their alternates, can be contacted at any time, on short notice. In addition, Plans are tested throughout the year in an effort to ensure that the Firm and its clients are provided with a recovery solution most conducive to their needs.

The Firm relies on the availability, capacity, and reliability of information technology. Each primary computer center has a corresponding back-up/disaster recovery site that is established away from the Firm’s primary facilities. The Firm’s computer centers are equipped with stand-alone electrical power and cooling capabilities sufficient to run for several weeks without relying on utility power. In an effort to ensure that applications are restored within a period of time acceptable to the business, applications have been prioritized, and their recovery requirements are based off of that prioritization.

The Firm’s incident management team is responsible for the coordination of communication and response procedures in the event of a disruption or possible disruption to normal operations. Included in the incident management team’s responsibilities is the communication of the Plans with regulatory agencies and key business partners. Members of the incident management team, and its procedures and protocols, have been documented in the Plans.

Pertinent updates to this disclosure statement will be posted on the Firm’s websites, as required by applicable law or regulation. Hard copies of the disclosure statement can be obtained by contacting your representative of the Firm.

The Plans are confidential and proprietary in nature and are therefore not made available for public distribution.

RBC Capital Markets, LLC (“RBCCM LLC” or the “Firm”) is committed to protecting its employees, clients and their assets at all times, including during emergencies or significant business disruptions. The Firm’s Enterprise Business Continuity Program has been developed to provide a reasonable, but not absolute, assurance of business continuity in the event of a disruption to the Firm’s normal operations.

RBC Correspondent Services and/or RBC Advisor Services, divisions of RBC Capital Markets, LLC, Member NYSE/FINRA/SIPC provides clearing and execution services and/or custody services for accounts managed by your financial advisor. The referenced product or service is available through that relationship.

© 2017 RBC Capital Markets, LLC. All rights reserved. 01101-CAS (02/17)

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