Brownstone Investment Group LLC’s Business Continuity Plan Disclosure
Our Business Continuity Plan – Brownstone Investment Group, LLC (“Brownstone”) maintains a Business Continuity Plan (BCP) in accordance with FINRA Rule 4370. Our BCP details how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions are unpredictable, we will have to be flexible in responding to actual events as they occur. We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data backup and recovery; all 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 if we are unable to continue our business.
Our clearing firms, Goldman, Sachs & Co. and Pershing, LLC, back up our important records in geographically separate areas, as we also do. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments within a reasonable time period based on the degree of disruption and magnitude to the general financial community. Your orders and requests for funds and securities could be delayed during this period.
Contacting Us – If after a significant business disruption you cannot contact us as normal at (212) 905-0550, you should call our alternative number (212) 661-0033 or go to our web site at http://www.brownstone.com for additional contact information or instructions. Please note that Brownstone is an Introducing Broker and as such does not maintain custody of customers’ funds or securities. If you cannot access us through either of those means, you should contact our clearing firms for instructions on how they may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions. Our clearing firms’ contact information: Goldman, Sachs & Co. at 212-357-2260 or visit their website at http://gsec.gs.com or Pershing, LLC, at 201-413-4800 or visit their website at http://www.pershing.com.
Varying Disruptions – Significant business disruptions can vary in their scope. They can affect only our firm, a single building housing our firm, the business district(s) where our firm is located, the cities where we are located or whole regions. Within each of these areas, the severity of the disruption can also vary from minimal to severe. As Brownstone operates offices in several different geographic areas, the Firm may be able to transfer operations to an office not affected. In a disruption to only our firm or a building housing our firm, we will transfer our operations and expect to recover and resume business within two hours. In a broader disruption we will transfer our operations to a site outside of the affected area, and recover and resume business within twenty-four hours. In either situation, we plan to continue in business, transfer operations to our clearing firms if necessary, and notify you through our web site http://www.brownstone.com on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
For more information – If you have questions about our business continuity planning, you can contact us at (212) 905-0550.