2008 Business Continuity Plan
Introduction
In accordance with FINRA Rule 3510, broker/dealer firms are required to create and maintain a business
continuity plan (“Plan”) that shall identify procedures relating to an emergency or significant business
disruption that are "reasonably designed to enable the member to meet its existing obligations to
customers." In addition, such procedures must address a firm’s existing relationships with other brokerdealers
and counter-parties, as well as be available promptly upon request of FINRA staff.
The purpose of the Plan is to help to ensure that the Firm will be able to continue its business in the event
of future significant business disruptions. A significant business disruption can be any situation, which
may temporarily disrupt the Firm’s operations and/or cause the Firm to promptly resume its business
operations at an alternate off-site facility. Examples of a significant business disruption can range from
man-made disruptions such as terrorist attacks, to natural disasters such as a fire, flood, earthquake,
hurricane, etc. It is the Firm’s belief that the implementation of this Plan is essential to investor protection
and overall market integrity.
Basic Requirements
In preparation of a properly completed Plan, the Firm has considered certain fundamental requirements in
order to adequately address all relevant factors as they pertain to the Firm’s size, scope and function.
Therefore, the following information provides an operational definition of each of the three fundamental
requirements:
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Written Business Continuity Plan. A firm must create and maintain a written business continuity
plan identifying procedures to be followed in the event of an emergency or significant business
disruption. The business continuity plan must be made available immediately upon request by a
federal, state and/or SRO regulatory agency.
Emergency Contact Information. A firm shall document and record appropriate primary and
secondary emergency contact information. The emergency contact information for the firm
includes designation of two emergency contact persons. Each emergency contact person shall
be a member of senior management or other authorized person of a firm. Each firm must update
its emergency contact information, via such electronic or other means, in the event of any
material change, but at a minimum must review the information contained therein annually to
ensure its accuracy.
Annual Review. A firm must conduct an annual review of its business continuity plan to determine
whether any modifications are necessary in light of changes to the firm’s operations, structure,
business and/or location. |
Firm Profile
Mayfair Securities, LLC (“Firm”) a securities broker/dealer registered with the FINRA which currently
maintains a minimum net capital requirement of $5,000 pursuant to SEC Rule 15c3-1(a)(2)(vi) of the Net
Capital Rule, and operates pursuant to SEC Rule 15c3-3(k)(2)(i) of the Customer Protection Rule. The
Firm currently maintains one OSJ (main) office and employs approximately ten (10) registered personnel.
In accordance with the Firm’s current FINRA membership agreement, the Firm is approved to engage in
the following securities business, whether or not it is currently conducting a business in such areas:
• Private Placements; and
• Merger & Acquisition Services.
Data Back-up and Recovery (Hardcopy and Electronic)
Location of Books and Records
The primary location of the Firm’s books and records will be maintained at its primary place of business
(see below). Back-up copies may also be maintained at and/or transferred to an alternate off-site facility
(please see Alternate Back-up Location for further details) in the event of any significant business
disruptions encountered by the Firm. The Firm will retain copies of all relevant books and records in
hardcopy and electronic format (back-up tape) for immediate access.
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Primary Firm Address |
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Contact Information:
William Pinney
Principal
pinney@mayfairsecurities.com |
Address:
Mayfair Securities, LLC
333 South Hope Street, 16th Floor
Los Angeles, CA 90071
Tel (213) 576-1050
Fax (213) 576-1100 |
Alternate Back-up Location(s)
The Firm’s books and records will also be maintained at the Firm’s alternate back-up office locations (see below). The Firm will retain copies of relevant books and records, some of which are maintained in
hardcopy and/or electronic format (tape format) for immediate access.
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Alternate Location #1
(*Secondary/Back-up site in the event of a significant business disruption to the Firm
and/or building for which the firm is located) |
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Contact Information:
William Pinney |
Office Address:
4073 Chevy Chase Drive
La Canda, CA 91011
Tel (818) 952–5035 |
Description of Record keeping System
Financial transactions will be documented and recorded at the time of the transaction and all such
documentation will be initialed and dated by the person responsible for reviewing each transaction.
Whenever possible, documents will be numbered and recorded to assist in document accountability.
Internal verification of financial reporting requirements shall be implemented for review, comparison, and
reconciliation of data and prepared by accounting personnel. Mr. Pinney and/or other such designated
and authorized persons will conduct such a review and verification on a continuous basis. Additionally, all
bank statements are reviewed by Mr. Pinney and Mr. Haigh for an independent review of transactions
before reconciliation. This control measure directly contributes to eliminating unapproved transactions
and monitoring potential fraud.
Data Back-up Process
The Firm currently conducts a back-up copy of all relevant client information monthly. All client data is
stored on the Firm’s computer server and on back-up CD. All relevant client information is saved to a CD back-up which is appropriately labeled and serialized for proper recording and organization of each backup
file. Upon completion of each back-up copy, the Firm stores each tape back-up file at the alternate
off-site facility and at a designated secured storage facility.
Recovering Lost Data
In the event the Firm experienced a significant business disruption, the Firm would obtain the most recent
(monthly) copy of its back-up files from the host server to reproduce its financial records or continue its
financial recording.
Mission Critical Systems
In accordance with Rule 3510, the term "mission critical system" can be any system that is necessary,
depending on the nature of a firm's business, to ensure prompt and accurate processing of securities
transactions, including, but not limited to, order taking, order entry, 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.
Resource Planning for Operating in Emergency Preparedness Mode
In the event that the Firm experiences a significant business disruption, the Firm will consider several
mission critical systems for operating in emergency preparedness mode:
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Business Facilities
The Firm’s primary place of business (Primary Office) is located in an office building, which is
near an established business area in Los Angeles, California with access to major freeways. The
office has all appropriate business facilities and amenities to include telephone and fax lines, as
well as access to the Internet. There is adequate space for conducting general securities
business, and for other key personnel to work comfortably in such a work environment. The
secondary office location (see Alternate Back-up Location) is also sufficiently equipped to
accommodate basic operational and logistical capabilities and requirements under emergency
circumstances.
Scheduling and Staffing
Due to its relative size, scope and function, the Firm is permitted to operate with a total of ten (10)
registered representatives. The Firm does not expect to exceed the maximum allowable number
of registered persons at this time. Additionally, in the event of a significant business disruption,
the Firm does not anticipate employing additional members or a contingent staff to resume
operations. Therefore, no major staffing or scheduling issues will be encountered by the Firm.
Firm Supplies and Materials
All supplies and materials to be used in the Firm’s operations are to be maintained at the primary
(main) office location. However, an adequate supply of materials shall also be maintained at the
designated alternate back-up facility (Alternate Site Location) for future use. For example, the
Firm will maintain stationary supplies, account document supplies, books and records supplies,
procedures, and other relevant supplies and materials at such locations.
Temporary Hardware and Software
In the event that the Firm experiences a significant business disruption, the Firm will utilize its
back-up hardware and software systems located at the designated off-site facility (Alternate
Office). The Firm maintains back-up desk-top computers and/or laptop computers as temporary
hardware for the designated back-up facilities. All business computers operate on specific hardware/software systems (see below) to accommodate incoming files and documents as well
as system capacity issues.
Hardware/Software Implementation
Hardware/Software:
The Firm uses a combination of different computer hardware components and systems software
for the general operations of the Firm. All hardware is separated by Networking, Server
Administration, Peripheral Support, and PC Support. Most of the Firm’s individual computer
workstations are using Microsoft Office (XP Pro) system software.
Order Taking
As previously stated, in accordance with the Firm’s current FINRA membership agreement, the
Firm is approved to engage in private placements and merger and acquisition services.
Therefore, the Firm is capable of receiving orders from customers via telephone, fax and/or email,
or through in-person visits by the customer. During an significant business disruption, either
internal or external, the Firm will continue to take orders through any of these methods that
continue to be available and accessible, and in addition, as communications permit, the Firm will
inform its customers when communications become available to tell them what alternatives they
have to send their orders to us. Customers will be informed of alternatives either by telephone
fax and/or e-mail.
Therefore, the Firm is capable of receiving orders from customers via telephone or through inperson
visits by the customer. During a significant business disruption, either internal or external,
the Firm will continue to take orders through any of these methods that continue to be available
and accessible, and in addition, as communications permit, the Firm will inform its customers
when communications become available to tell them what alternatives they have to send their
orders to us. Customers will be informed of alternatives either by telephone, fax and/or e-mail. If
necessary, the Firm will advise its customers to place orders directly with the private placement
company.
Order Entry
Currently, the Firm enters orders by recording them on paper (subscription documents). In the
event of a significant business disruption, the Firm can expect certain delays when processing
orders under these circumstances.
Order Execution
Based on the Firm’s approved investment products, the Firm does not execute orders nor does it
have a clearing arrangement with a designated clearing firm. The Firm currently executes orders
directly through the designated escrow agent. In the event of an internal and/or external
significant business disruption, the Firm would sustain little impact because of its direct business.
However, in the event that the Firm’s existing systems are inoperable, the Firm would transfer to
one of the alternate off-site facilities to continue to process transactions. |
Financial and Operational Assessments
In accordance with Rule 3510, the term “financial and operational assessments" is a set of written
procedures that allows a firm to identify changes in its operational, financial, and credit risk exposures.
Operational risk is the Firm's ability to maintain communications with customers and to retrieve key
records through its mission critical systems. Financial risk relates to the Firm's ability to continue to
generate revenue and to retain or obtain adequate financing and sufficient equity.
Firm Operations
The Firm is permitted to operate with a total of ten (10) registered representatives. Current broker/dealer
operations are conducted at the Firm’s Primary Office. The principal place of business is located in an
office building, which is near an established business area near Los Angeles, California. In the event of a
significant business disruption, the Firm will promptly identify all available means which will allow for the
continued communication with its customers, employees, critical business constituents, critical banks,
critical counter-parties, and regulators. Although the effects of a significant business disruption will
determine the means of alternative communication, the communications options that the Firm chooses to
employ will include the use of the telephone, e-mail, and the Internet.
Financial and Credit Risk
In the event of a significant business disruption, the Firm will promptly assess the value and liquidity of its
investments and any other relevant assets to evaluate the Firm’s ability to continue to fund its operations
and remain in compliance with the net capital rule. Upon evaluation, the Firm will contact its designated
banks and investors to apprise them of its financial status. If the Firm determines that it may be unable to
meet its obligations to those counter-parties or unable to continue to fund its current operations, the Firm
may request additional financing from its bank or other credit sources (e.g. forgivable and/or nonforgivable
loans from principal shareholders, etc.) to fulfill its obligations to its customers and clients. If
the Firm cannot remedy a capital deficiency, it will make all appropriate notices and/or filings with its
designated examination authority and other appropriate regulators.
Financial Controls
As the designated Chief Compliance Officer, Mr. Pinney and the designated FINOP, Mr. Haigh will
maintain responsibility for the preparation and maintenance of the firm’s financial records. The Firm’s
financial information will be maintained at the Firm’s principal place of business (Primary Office) on
specific accounting software (see below). All of the firm’s financial information will be maintained on
computer and backed-up on a host server, and will not be stored on any shared server or other shared
environment. All of the Firm’s business checks will be maintained in a secured area at the main office and
at an alternate off-site location. All of the electronic financial files will be password protected for security
purposes, and only authorized persons will have access to the Firm’s financial information.
Check signing responsibilities shall be limited to only authorized persons. Mr. Pinney will also be
responsible for the processing and recording of checks and ledgers in addition to the approval of vendors
to be paid and their respective amounts. This control measure contributes directly to eliminating
unapproved transactions and monitoring potential fraud.
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Accounting Software Implementation
Accounting Software:
The Firm currently uses Microsoft Money version 2003 to record and account for its financial
transactions. All Firm financials are properly recorded and backed-up on a host server. |
Communications Systems and Methods
Communications and Operations Systems
The Firm utilizes commercial grade Windows-based personal computer systems with a minimum of
DSL/Cable Internet modem access to assure the most reliable and efficient means of facilitating account
systems. These include, but are not limited to personal desktop computers, server hardware, PC
uninterrupted power supply, anti-virus software, encryption software, and DSL data connections.
The Firm will employ the Internet in accordance with common practices of communicating with clients and
general business contacts.
The Firm will not employ the Internet or any other electronic means to
conduct securities trades outside the scope of its normal business operations unless otherwise disclosed.
The Firm will also employ the use of a local telephone system as its primary telecommunications system
to communicate with clients and other business contacts. One or more back-up connections are located
throughout the office in the event of extended power outages or other disruptions in the use of the primary
system. Cellular phones may also act as an alternate communications device in the event the primary
system is inoperable.
All such communication and operation systems will be employed by the Firm to ensure fluid business
continuity, including but not limited to, system capacity issues, to handle the anticipated level of usage;
contingency plans in the event of systems or other technological or communications problems or failures;
system redundancies; disaster recovery plans; and system security issues.
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Alternate Communications between the Firm and its Customers
The Firm will employ the use of a local telephone system as its primary telecommunications
system to communicate with clients and other business contacts. E-mail and cellular phones may
also act as a secondary (alternate) means of communication in the event that the primary
telephone system is temporarily or permanently inoperable. A back-up connection is also located
at the alternate site(s) in the event of extended power outages or other disruptions in the use of
the primary system. In the event of a significant business disruption, the Firm will make every
effort and attempt to contact its clients within forty-eight (48) hours to notify them of the alternate
contact information and the location of the alternate site(s).
Alternate Communications between the Firm and its Employees
The Firm currently communicates with its employees using a variety of methods such as the
telephone (including cellular phones), e-mail, and in person. The Firm will request that all key
personnel and staff have cellular phones to facilitate the communication process in the event of a
significant business disruption.
In the event of a significant business disruption, the Firm will assess which means of
communication are available, and use the means closest in speed and form (written or oral) to the
means that the Firm has used in the past to communicate with the other party. The Firm will also
employ a Priority Contact List so that senior management can reach all employees quickly during
a significant business disruption. The Priority Contact List may include office, home and cellular
phone numbers of key personnel to ensure proper notification and resumption procedures
(Please see Priority Contact List as attached for further details). |
Alternative Physical Location of Employees
In accordance with FINRA Rule 3510(c)(6), the Firm must disclose one or more alternate physical
locations from which employees will resume business operations. Therefore, in the event of a significant
business disruption, the Firm will transfer its key personnel from any affected offices to the predesignated
alternate off-site facility or facilities which are unaffected by the disruption (see Alternate
Back-up Location(s) above for address and contact information).
Critical Business Constituent, Bank, and Counter-Party Impact
Business Constituents
The Firm has established procedures that assess the impact that a significant business disruption would
have on critical business constituents (businesses with which the Firm has an ongoing commercial
relationship in support of its operating activities), banks (lenders), and counter-parties (e.g., other brokerdealers
or institutional customers). In addition, the Firm provides for alternative actions or arrangements
with respect to their contractual relationships with business constituents, banks, and counter-parties in the
event of a material business disruption to either party.
The Firm will contact all critical business constituents to determine the extent to which the Firm can
continue its business relationship with them in the event of an internal or external significant business
disruption. The Firm will quickly establish alternative arrangements if a business constituent can no
longer provide the necessary goods or services due to a significant business disruption. At this time, the
Firm has elected not to enter into any supplemental contracts, or use any alternative suppliers under
conditions of a significant business disruption because such arrangements appear unnecessary based on
the Firm’s size, scope and operational function.
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Clearing Firm
Based on the scope of services to be provided, the Firm does not employ the services of a
clearing firm at this time.
Banks
The Firm will contact all relevant banks and/or lenders (those currently maintaining accounts on
behalf of the Firm) to determine if they are capable and willing to provide any needed financial
assistance to continue the Firm’s operations in the event of an internal or external significant
business disruption. If the Firm’s banks and other lenders are unable to provide financial
assistance, the Firm will seek alternative financing immediately from one or more local banks or
directly from the principal shareholders of the Firm. |
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Key Banking Relationships
The Firm has an established banking relationship with its Designated Bank (see below),
which handles the Firm’s business checking and saving accounts. No other key banking
relationships exist at this time. In the event that the Firm experiences a significant
business disruption, the Firm will contact its designated bank immediately or at least
within twenty-four (24) hours to ensure access to funds and that the designated bank is in
operating order.
The following information is a list of the designate bank(s) for which the Firm maintains a
banking relationship:
Designated Bank
Contact Information:
Dina Owens |
Local Branch:
Northern Trust
355 South Grand Avenue
Los Angeles, CA 90071
(213) 346-1479
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Counter-Parties
The Firm will contact all relevant critical counter-parties, such as other broker/dealers or
institutional customers, to determine if it will be able to complete its transactions in light of the
internal or external significant business disruption. Where the transactions cannot be completed,
the Firm will contact those counter-parties directly to make alternative arrangements to complete
those transactions as soon as possible. |
Regulatory Reporting
The Firm serves as a FINRA member broker/dealer. The Firm is also registered to conduct a securities
business in California. Therefore, the Firm operates under the regulatory jurisdictional authority of the
FINRA, SEC and applicable state securities agencies. The Firm currently files reports and otherwise
communicates with regulators using hardcopy documents by U.S. mail, and electronically using fax, email, and the Internet. In the event of a significant business disruption, the Firm will check with the SEC,
FINRA, and other state regulators to determine which alternate means of filing are still available and which
methods are most similar and appropriate under the circumstances (please see Regulator Contact List as
attached). In the event that the Firm cannot contact regulators, the Firm will continue to file required
reports using the normal communication means available to it.
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Central Registration Depository (CRD) System
The Central Registration Depository, called the CRD (Web CRD® system), is a computerized
database where the FINRA maintains the qualification, employment, and disclosure histories of
registered securities employees, and certain information about the firms they work for. Therefore,
the Firm relies on the Web CRD system for several regulatory reporting functions such as (i)
Entitlement Processing; (ii) Form U-4/U-5 Filings; (iii) FINRA Rule 3070 Filings; (iv) FOCUS
Filings; (v) Form BD Amendments; (vi) Regulatory Element CE Notifications; Daily/Renewal
Account Funds Verifications; and other required filings.
It is the responsibility of the designated supervisory principal and/or account administrator to file
one or more of the required regulatory filings as described above. Historical filings are maintained
on the CRD system for future use and retrieval purposes. In the event that the Firm experiences a
significant business disruption, the Firm will attempt to access the CRD system through its User
Name and Password information within twenty-four (24) hours to ensure the CRD system is in
operating order. The Firm may also maintain hardcopies of certain filings for future use.
Annual Financial Statements
The Firm will continue to file with the FINRA, SEC and applicable state regulatory agencies
financial statement information (e.g. annual financial audit Report; income statement, balance
sheet, and supporting financial documentation) as and when required. |
Communications with Regulators
Communications with Regulators
The Firm will maintain Internet access and telephone capabilities at the primary (main) office and the
designated secondary (alternate) off-site facilities. This will facilitate any required communications with
federal, state and/or SRO regulatory agencies. As an alternate method, the Firm will also maintain an
electronic (CD) and hardcopy list of all relevant regulatory offices such as the FINRA Headquarters and
local District Office, SEC Headquarters and local Regional Office, State Securities Agencies and any
other regulatory agencies with which the Firm may be affiliated (please see the Regulator Contact List)
Regulatory Inquiries
In the event of a formal or informal inquiry made by any federal, state, and/or self-regulatory organization
(SRO), the designated supervisory principal will be responsible for receiving all calls and/or other
requests as well as providing assistance and documentation to any regulatory requests or inquiries.
Prompt Access to Customer Funds and/or Securities
The Firm does not maintain custody of customers’ funds or securities. In the event of an internal or
external significant business disruption where telephone service is available, the Firm’s assigned
registered representatives will continue to receive customer orders or instructions via telephone or email.
In the event that telephone service is unavailable, the Firm will periodically post updates on its Web site
as to how and when customers may access their funds and/or securities through alternate preestablished
means. The Firm will also make this information available to customers through its disclosure
policy (see Business Continuity Plan Policy as attached).
Application of SIPC Rules
As a FINRA member broker/dealer, the Firm is also a member of the Securities Investor Protection
Corporation (SIPC). Therefore, in the event that a significant business disruption impairs the Firm’s ability
to provide sufficient liquidation of customer funds or securities resulting from a bankruptcy or other
financial difficulties, SIPC shall step in as quickly as possible and, within certain limits, works to return
customers' cash, stock and other securities. As such, if SIPC determines that the Firm is unable to meet
its obligations to its customers, or if the Firm’s liabilities exceed its assets in violation of Securities
Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse the Firm’s assets to
customers. The Firm will assist SIPC and the trustee by providing and/or making available the Firm’s
books and records identifying customer accounts subject to SIPC regulation.
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Rules Relating to Satisfaction of a “Claim for Cash” or a “Claim for Securities”
These rules will be applied in determining whether a securities transaction gives rise to a “claim
for cash” or a “claim for securities” on the filing date of either a liquidation proceeding or a direct
payment procedure pursuant to the Securities Investor Protection Act.
Claim for Cash
Where the Firm held securities in an account for a customer, the customer has a “claim for cash”
with respect to any authorized securities sale: (1) if the Firm has sent written confirmation to the
customer that the securities in question have been sold for or purchased from the customer’s
account; or (2) whether or not such a written confirmation has been sent, if the securities in
question have become the subject of a completed or executory contract for sale for or purchase
from the account.
Where the Firm held cash in an account for a customer, the customer has a “claim for cash,”
notwithstanding the fact that the customer has ordered securities purchased for the account,
unless: (1) the debtor has sent written confirmation to the customer that the securities in question
have been purchased for or sold to the customer’s account; or (2) whether or not such a written
confirmation has been sent, if the securities in question have become the subject of a completed
or executory contract for purchase for or sale to the account.
Claim for Securities
Where the Firm held cash in an account for a customer, the customer has a “claim for securities”
with respect to any authorized securities purchase: (1) if the Firm has sent written confirmation to
the customer that the securities in question have been purchased for or sold to the customer’s
account; or (2) whether or not such a written confirmation has been sent, if the securities in
question have become the subject of a completed or executory contract for purchase for or sale
to the account.
Where the Firm held securities in an account for a customer, the customer has a “claim for
securities,” notwithstanding the fact that the customer has ordered the securities sold for the
account, unless: (1) the Firm has sent written confirmation to the customer that the securities in
question have been sold for or purchased from the customer’s account; or (2) whether or not
written confirmation of the purchase has been sent, if the securities in question have become the
subject of completed or executory contract for sale for or purchase from the account. |
Emergency Contact Information
In accordance with FINRA Rule 3520, the Firm currently reports to FINRA certain emergency contact
information, which includes the designation of two emergency contact persons. Each emergency contact
person is a member of senior management and a registered principal of the Firm.
The Firm will promptly update its emergency contact information through the NCS system in the event of
any material change. The Firm will review and, if necessary, update its emergency contact information,
including the designation of two emergency contact persons, within 17 business days after the end of each calendar quarter to ensure the information's accuracy. The Firm's Executive Representative or other
appropriately designated and authorized principal will conduct such reviews and any necessary updates.
The Firm has assigned a primary and secondary emergency contact person (see below) as required. As
the primary contact person of the Firm, Mr. Pinney shall maintain responsibility for ensuring that the Plan
is implemented in accordance with all stated initiatives and objectives herein.
All relevant information shall be directed to the following primary and/or secondary emergency contact
person(s) for internal review, implementation and follow-up:
Primary Contact Person
Contact Information:
William Pinney
Principal
pinney@mayfairsecurities.com
| Office Address:
Mayfair Securities, LLC
333 South Hope Street, 16th Floor
Los Angeles, CA 90071
Tel (213) 576-1050
Fax (213) 576-1100 |
Residence:
4073 Chevy Chase Drive
La Canada, CA 91011 |
Secondary Contact Person
Contact Information:
Richard Haigh
Principal
haigh@mayfairsecurities.com
| Office Address:
Mayfair Securities, LLC
333 South Hope Street, 16th Floor
Los Angeles, CA 90071
Tel (213) 576-1051
Fax (213) 576-1100 |
Residence:
12743 Landale Street
Studio City, CA 91604 |
Annual Review and Updates
The Firm will conduct an annual review of its Plan to determine whether any modifications are necessary
in light of changes to the Firm’s operations, structure, business and/or location. The Firm will also
periodically assess any changes in certain financial and operational exposures (as described above),
quickly assess the situation, and take appropriate action relative to a significant business disruption.
Currently, Mr. Pinney, as a member of senior management, will review the Firm’s Plan during the fourth
quarter (Q4) of each fiscal year to determine whether any revision or updating is needed. In the event
that the Plan requires updating, Mr. Pinney will add, change or revise certain language in the Plan so it is
currently aligned with the Firm’s internal needs and regulatory requirements. Upon review and updating,
the final Plan will be approved by Mr. Pinney on an annual basis. An updated copy of the Plan will be
distributed to each affiliated person of the Firm upon completion.
Disclosure Requirements
In accordance with FINRA Rule 3510(e), the Firm will disclose to its customers how its business continuity
plan addresses the possibility of a future significant business disruption and how it plans to respond to
events of varying scope. In addressing the events of varying scope, the Firm has provided the following
disclosures: (1) provide 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) state whether it plans to continue business during that scenario and, if so, its
planned recovery time; and (3) provide general information on its intended response. The disclosure will,
at a minimum, be made in writing to customers upon account opening and mailed to customers upon
request (please see the Firm’s Business Continuity Plan Disclosure Policy as attached).
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A Disruption to the Firm and/or Single Building
In the event that there is a significant business disruption to the firm and/or the building in which
the Firm is located, the Firm has duplicative systems that will be operated from a separate back up (“alternate”) site. This disruption may be caused by physical damage, technology problems, or
an inability to have personnel arrive at the office. As such, the Firm will transfer its securities
operations to one or more designated alternate site(s) located in the same city or in adjoining
cities that are sufficiently separated the Firm’s main operations. The alternate site will be used to
restore internal operations as well as electronic access and communications as soon as key
employees are relocated to the designated sites. In this process, Clients may experience a minor
delay in reaching the Firm due to increased telephone calls, technology delays, or other minor
difficulties arising from the transfer of operations. The Firm expects that any delay will be less
than twelve (12) hours. Nevertheless, the unlikely failure of the telephone or other ancillary
communication systems could result in a delay of up to twenty-four (24) hours.
A Business-District, Citywide, or Regional Disruption
In the event there is a significant business disruption that affects the business district or city
where any of the Firm’s primary systems are located, the Firm will transfer operations to its
designated back-up (“alternate”) site located in separate and distinct business district and city
from the Firm’s main operations (see Alternate Location). The alternate site will be used to
restore internal operations as soon as key employees are relocated to the site.
In the event of a significant business disruption to the region where the Firm’s primary systems
are located, the Firm would intend to take advantage of any available branch or other facilities
that may be located in other geographical regions to use in limited capacity to resume operations
temporarily (see Alternate Location). As a secondary back-up, the Firm may enter into a “BCP
Joint Pact” with another broker/dealer or similar firm that currently operates in an adjoining region
that will effectively leverage the use of technology and infrastructure to continue operations.
Under the BCP Joint Pact, the selected firm will be determined as sufficiently capable to operate
as a designated back-up facility. In this process, Clients may experience minor delays in reaching
the Firm due to increased telephone calls, technology delays, or other minor difficulties arising
from the transfer of operations. The Firm expects that any delay will be less than 24 hours.
Nevertheless, there can be no assurance that service will continue without interruption in certain
circumstances, such as a regional blackout, a natural disaster or a terrorist attack. However, in
the unlikely event that the Firm has determined that it cannot resume operations within a
reasonable amount of time; it will provide as much advance notice as possible regarding its
ongoing operations.
Please be advised that the MSL’s BCP is reviewed and updated on an annual basis and subject
to change and modification. Therefore, any changes and updated information will be promptly
sent to customers. Alternatively, customers may obtain a copy of MSL’s business continuity plan
by requesting a written copy in writing.
Additionally, our primary internal and external application and service 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 clients is extremely important
to us, and our business continuity plan is designed to allow us to continue to provide the quality
service to all of our clients.
Priority Rep. Contact List
|
Regulator Contact List
FINRA
| Name |
Telephone |
Fax |
Website |
| District 2 (Los Angeles, CA) |
213-229-2300 |
213-617-3299 |
www.finra.org |
Securities and Exchange Commission (SEC)
State Regulatory Agencies
| State |
Telephone |
Fax |
Website |
| California |
916 445-7205 |
916 445-7975 |
www.corp.ca.gov |
Business Continuity Disclosure Policy
Mayfair Securities, LLC (“MSL”) is a FINRA registered broker/dealer providing brokerage services to its
customers. Accordingly, the Firm is furnishing this document to all clients to provide information about
its efforts to ensure that MSL securities operations will not be significantly impacted 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, MSL has designed a business continuity plan to address possible scenarios
in efforts to minimize any service impact to our clients.
In keeping with the regulatory requirements, the business continuity plan for MSL 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 MSL and its customers;
• Alternate means of communication between MSL and its employees;
• Alternate physical locations of employees;
• Critical business constituent, bank and counter-party impact;
• Regulatory reporting;
• Communications with regulators; and
• How MSL will ensure that customers have access to their funds and securities in the event that
MSL determines it is unable to continue its business.
Since events creating business disruptions may vary in nature and scope, MSL has anticipated
scenarios in which the following are affected:
• A disruption to MSL’s primary or main office location
• A disruption to a single building in which MSL’s main office is located
• A disruption to the business district or city where MSL’s primary systems are located
• A disruption to the region where MSL’s primary systems are located
Regardless of the scope of potential disruption, MSL intends to continue to provide service to its
clients.
A Disruption to the Firm and/or Single Building
In the event that there is a significant business disruption to the firm and/or the building in which the
Firm is located, MSL has duplicative systems that will be operated from a separate back-up
(“alternate”) site. This disruption may be caused by physical damage, technology problems, or an
inability to have personnel arrive at the office. As such, MSL will transfer its securities operations to
one or more designated alternate site(s) located in the same city or in adjoining cities that are
sufficiently separated from MSL’s main operations. The alternate site will be used to restore internal
operations as well as electronic access and communications as soon as key employees are relocated
to the designated sites. In this process, Clients may experience a minor delay in reaching MSL due to
increased telephone calls, technology delays, or other minor difficulties arising from the transfer of
operations. MSL expects that any delay will be less than twelve (12) hours. Nevertheless, the unlikely
failure of the telephone or other ancillary communication systems could result in a delay of up to twenty-four (24) hours.
A Business-District, Citywide, or Regional Disruption
In the event there is a significant business disruption that affects the business district or city where any
of MSL’s primary systems are located, MSL will transfer operations to its designated back-up
(“alternate”) site located in separate and distinct business district and city from MSL’s main operations
(see Alternate Location). The alternate site will be used to restore internal operations as soon as key
employees are relocated to the site.
In the event of a significant business disruption to the region where MSL’s primary systems are
located, MSL would intend to take advantage of any available branch or other facilities that may be
located in other geographical regions to use in limited capacity to resume operations temporarily (see
Alternate Location). As a secondary back-up, MSL may enter into a “BCP Joint Pact” with another
broker/dealer or similar firm that currently operates in an adjoining region that will effectively leverage
the use of technology and infrastructure to continue operations. Under the BCP Joint Pact, the
selected firm will be determined as sufficiently capable to operate as a designated back-up facility. In
this process, Clients may experience minor delays in reaching MSL due to increased telephone calls,
technology delays, or other minor difficulties arising from the transfer of operations. MSL expects that
any delay will be less than 24 hours.
Nevertheless, there can be no assurance that service will continue without interruption in certain
circumstances, such as a regional blackout, a natural disaster or a terrorist attack. However, in the
unlikely event that MSL has determined that it cannot resume operations within a reasonable amount
of time; it will provide as much advance notice as possible regarding its ongoing operations.
Please be advised that the MSL BCP is reviewed and updated on an annual basis and subject to
change and modification. Therefore, any changes and updated information will be promptly sent to
customers. Alternatively, customers may obtain a copy of MSL business continuity plan by requesting
a written copy in writing.
Additionally, our primary internal and external application and service 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 clients is extremely important to us,
and our business continuity plan is designed to allow us to continue to provide the quality service to all
of our clients. |
