Pipeline is obligated to satisfy the mandates of NASD Business Continuity Plan (“BCP”) Rules 3510 and 3520. Regardless of this requirement, Pipeline recognizes its obligations to its clients – ensuring them that, in the event of a serious business disruption (SBD), they can be assured of the:
- integrity of their executed orders,
- accurate and complete communications concerning their transactions,
- restoration of normal business continuity,
- clearance and settlement of their pending trades,
- safety of their assets.
This is a summary of the procedures and responsibilities described in detail in our formal BCP. Pipeline’s BCP outlines core business and functional procedures to be recovered and/or relocated in response to varying levels of business disruptions, namely a SBD occurring at:
- Pipeline’s principal office,
- the office(s) of our service agencies,
- in the immediate New York City area,
- in a broader geographical area.
Our BCP provides explicit procedures for:
- emergency communications between employees, customers, and regulators,
- maintenance of critical applications,
- maintenance of banking and vendor relationships,
- retrieval and back-up maintenance of vital records,
- continuance of regulatory reporting including emergency reporting requirements,
- ensuring our customers’ prompt access to their assets and records.
Pipeline intends to conduct its operations during a SBD that affects only Pipeline Trading or the building in which we are located. We have identified alternative locations and resources for our current business-critical services that are independent of a particular physical location. Pipeline has formulated plans that could be implemented immediately. The plans and facilities for executing such plans effectively mirror our daily operations at a remote out-of-state location in the eastern region of the United States. These facilities are located over 200 miles from our main facilities in order to provide you with continuity of service should a SBD occur in an extended geographic location. Key employees have been assigned to manage interim operations at any and all of our contingency locations.
In the event a SBD affects the local business area or a broader geographic region, Pipeline has identified and prioritized the resumption of its core services during the period of the disruption. Alternative service support and processing locations have been identified that would be available to us provide core services to our clients until our primary location is fully operational. In the event of an industry-wide SBD, Pipeline’s goal is to resume essential business operations within hours after the SBD occurs. If that is not feasible, our objective is to provide day-to-day processing and support within one business day following the resumption of key industry services by the exchanges and clearing and depository agencies.
In the event a SBD necessitates the implementation of Pipeline’s BCP, every reasonable attempt will be made to restore and maintain normal service levels as soon as practicable. Please note however, our ability to do so will depend on whether other financial market participants and critical infrastructures e.g., clearing systems and/or public utilities, will remain operational.
The Pipeline BCP will be periodically modified to improve its effectiveness and will be re-certified annually as required by FINRA. We welcome the opportunity to address any questions that you may have. Please contact us directly at compliance@pipelinetrading.com.
