The policy of Guggenheim Securities, LLC is to respond to a future significant business disruption (“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 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 any funds or securities due to them.
We have developed a Business Continuity Plan that details the efforts we will make to address any SBD, whether it is internal or external in nature. This document summarizes the plan and the actions we will take to address any SBD quickly and efficiently.
Business continuity contacts
In the event of an SBD, all of our employees will be immediately notified by one of our SBD Crisis Response Team members. The SBD Crisis Response Team Members are Paul Friedman, Ron Iervolino, George Tilghman, George Raab and Dan Steuer. The team will be activated once an SBD has been declared.
Plan testing
The Plan will be tested at least semi-annually to ensure a state of readiness. The testing may include “live” testing that will employ the use of a disaster recovery site or it may be a paper-based test. The testing may be pre-announced or called without notice, at the discretion of the company’s management. Training will be implemented as necessary throughout the year to ensure compliance with the plan elements.
SBD scenarios
Once a potential SBD occurs, the Crisis Response Team and others will immediately set the plan in action. First, the safety of all employees will be considered. Second, data will be gathered on the SBD and the effects on systems and other resources. Finally, a decision will be made on which type of response will be employed.
A variety of scenarios have been considered in the development of the BCP. To highlight several of these, the following chart illustrates the severity of the SBD and the planned response, including response and resumption objectives.
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SBD scenario
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Temporary Internal SBD (Loss of power, fire, bomb threat, HVAC failure, etc.)
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Internal SBD (loss of power, phone, data/internet service building-wide)
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External SBD (loss of power, phone, data/internet service — regional)
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Duration
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< 4 hours
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> 4 hours
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> 4 hours
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Characteristics
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Internal systems outage, forced to evacuate building for less than 4 hours.
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Internal systems outage, forced to evacuate building for indeterminate amount of time.
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Due to external factors: systems outage, power outage, forced to evacuate building for indeterminate amount of time.
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Effect
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Communication with customers, clearing firm, vendors, banks limited to external systems (cell phones, blackberry’s, outside communication sources).
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Communication with customers, clearing firm, vendors, banks limited to external systems (cell phones, blackberry’s, outside communication sources).
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Communication with customers, clearing firm, vendors, banks limited to external systems (cell phones, blackberry’s, outside communication sources).
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Response
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Level 3 Response: Send abbreviated team to DR site to resume operations. All other employees will be instructed accordingly.
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Level 2 Response: Resume operations from DR site as soon as possible. All mission critical employees will report to DR site, others will work from alternate office sites.
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Level 1 Response: Resume operations from DR site as soon as possible. Notify customers and other key contacts of status. All mission critical employees will report to DR site, others will work from alternate office sites.
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Systems Response
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Use NY based back-up systems
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Use NY or Chicago based back-up systems; implement alt. telecommunications plan
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Use NY or Chicago based back-up systems; implement alt. telecommunications plan
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Response
Time
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60 - 90 minutes
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60 - 90 minutes
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60 - 90 minutes
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Resumption
Time
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90 - 120 minutes
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90 - 120 minutes
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90 minutes - 4 hours
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IT backup and storage
As part of normal operations, all systems and data stored on the network are being backed up on tapes every evening. These tapes are stored on 20-day rotations and a copy is stored off site every week in a storage facility managed by an outside storage company.
Business continuity
Guggenheim Securities, LLC is committed to responding to an SBD efficiently and effectively in order to resume business as normal as quickly as possible. We will do everything in our power to communicate with our customers, counterparties and other mission critical partners, the status of our operations as frequently as we deem necessary.
This plan is subject to modification. If the plan is modified, an updated summary will be promptly posted on our Web site. Customers may alternatively obtain updated summaries by requesting a written copy by mail.