Cross Point Capital, LLC (“CPC or the Firm”) maintains a Business Continuity Plan (the “Plan”) that sets forth a plan to respond to any disruption of business operations. CPC’s Plan is to respond to a Significant Business Disruption (an “SBD”) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and allowing the Firm’s customers to transact business. In the event that the Firm determines that it is unable to continue its business, the Firm will assure customers prompt access to their funds and securities to the extent applicable, as the Firm does not hold money or securities for customers or carry customer accounts.
The Plan addresses the following: data back-up and recovery; 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 and steps taken if we are unable to continue our business.
The Firm’s Plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the Firm’s ability to communicate and do business, such as a fire in the Firm’s 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. SBDs can vary in scope.
In the event of an internal or external SBD, and telephone service is available, our registered persons will take customer orders or instructions and contact our clearing firm on their behalf. If the Firm’s Web access is available, the Firm will post on its Web site a phone number or other communication venue that customers may use to contact CPC.
The Firm anticipates a SBD recovery time of 4 hours and a resumption time of activity within the same business day.
CPC does not hold customer funds or securities. All transactions for execution are sent to CPC’s clearing firm, Pershing LLC which executes the orders, compares them, allocates them, clears and settles them. Pershing has its own, independent business continuity plans for operations during any SBD and to recover following a SBD that affects it. Presently the Firm communicates with its customers using telephone, e-mail, its Web site, fax, U.S. mail, and in person visits at the Firm or at the customer’s location. In the event of an SBD, the Firm will assess which means of communication are still available to it and use the means closest in speed and form (written or oral) to the means that it has used in the past to communicate with the customer.
Further information regarding the Firm’s Business Continuity Plan is available upon request.