Business Continuity Plan Summary
Coastal Securities has developed a Business Continuity (BC) Plan that describes our planned response to events that significantly disrupt our business. Since the impact and severity of every disaster is impossible to predict, Coastal acknowledges that flexibility is key to any business continuity plan. With that in mind, we provide you with the following summary information with regard to our Business Continuity Plan. Please note that this information may be amended by Coastal, in its sole discretion, as material changes are made to Coastal’s infrastructure, operations and contingency plans.
Coastal has an approved plan of action that takes into account the safety of our employees, the safeguarding of our property, initiating financial and operational assessments, protecting the firm’s books and records, and allowing our customers to transact business and have access to their accounts at Pershing. We plan to quickly recover and resume business operations and have determined how our employees can continue to operate from Coastal’s private BC space located at our teleco’s data center or from one of our remote locations. Our goal is to deliver continuous, reliable service to our customers while maintaining regulatory compliance.
Our plan addresses:
- incident assessment
- disaster declaration
- data back up and recovery
- all mission critical systems
- financial and operational assessments
- alternative communications with customers, employees and regulators
- alternative physical location of employees
- critical supplier, contractor, bank and counter-party impact
- regulatory reporting
- client access to client funds and securities
Alternate Employee Communications
Coastal has developed several means of communicating with employees
- all supervisors carry updated contact information on their department employees, as well as contact information for senior management
- employee communications via Coastal’s intranet site
- routing of data and voice between Coastal’s BC and DR data centers to provide failover should one location become unavailable
- the management of the building where Coastal’s main office is located has emergency contact information that has been disseminated to all employees
All key personnel and their back ups have been equipped with laptop computers and/or mobile devices in order to continue communications and operations from Coastal’s BC space or remote locations. Key personnel may establish a central command post in Coastal’s private BC space at our teleco’s data center. In extreme cases certain personnel may be relocated of our Austin, San Antonio or Little Rock office if the Houston area is not a viable alternate location.
Client Access to Funds, Securities, Handling of Orders, Client Communication
Information for our clients will be posted to our website www.coastalsecurities.com as soon as possible following a disaster.
Clients will be directed to key personnel phone numbers to assist them in handling orders or gaining access to their funds and/or securities. We will make every effort to handle orders but, depending upon the nature of the disruption and the availability of critical resources (i.e. electricity, phones, and internet), we cannot guarantee that orders can be executed.
Clients with Pershing Accounts: If the disaster is of such magnitude that Coastal personnel are not available to assist, access to Pershing accounts and handling of orders may be accomplished by going directly to our clearing firm, Pershing LLC. In regard to their own contingency planning, Pershing has stated that all Pershing operational facilities are equipped for resumption of business and are tested. Regarding all circumstances within their control, Pershing’s recovery time objective (RTO) for business resumption, including those involving a relocation of personnel or technology, is four (4) hours, depending upon the availability of external resources. In the event that Coastal experiences a significant business interruption, clients may contact Pershing directly to process limited trade-related transactions, cash disbursements, and securities transfers. Instructions to Pershing must be in writing and transmitted via facsimile to (201) 413-5368 or by postal service as follows: Pershing LLC, P.O.Box 2065, Jersey City, NJ 07303-2065. Additional information on how to request funds and securities when Coastal cannot be contacted due to a significant business interruption is located in the Customer Support section
of Pershing’s website, or by phone (201) 413-3635 for recorded instructions. If these means are not available, please call (213) 624-6100, extension 500, as an alternate Pershing number for recorded instructions.
Clients with Loan Documents at, or in route to, Coastal’s office: In the event that a client has a question about the location and status of documents involved in an open loan transaction (and not a securities transaction), the client will need to contact a Coastal employee for assistance. Pershing is not involved with clearing these transactions and will not be able to answer any loan questions. Due to the physical nature of these transactions, loan documents may be difficult to locate if the building in which we are headquartered is disabled, damaged or no longer standing. Coastal will make every effort to find documents and complete the transaction or return them to the holder.
Data Strategy, Mission Critical Application Recovery and People
Coastal Securities stores and maintains its production servers, transactional data, critical applications and customer account information in a geographically dispersed, state-of-the-art, hardened BC data center. In support of Coastal’s DR Plan, Coastal maintains redundant equipment at our DR data center located 160 miles outside the city of Houston. The BC and DR data centers are available immediately at time of disaster (ATOD) to support the initiation of recovery efforts. Both data centers are equipped with extensive power generation and back up capabilities, dual HVAC, fire detection and prevention systems, proactive monitoring and surveillance from on-site personnel, and are operational 24/7/365. In addition, we have the ability to relocate associates and resume business functions at Coastal’s BC space or at one of Coastal’s alternate business locations in Austin, San Antonio or Little Rock.
Third Party Protection
Pershing and other third party vendors to Coastal provide another layer of recovery through their own disaster recovery platforms. Coastal has reviewed their business continuity plans and deems them appropriate and critical to Coastal’s Business Continuity Plan.
Banks and Significant Counter-Parties
Under Coastal’s Business Continuity Plan, the firm anticipates that it will maintain contact and/or connectivity with all critical counter-parties. However, it is noted that Coastal’s plan will be dependent upon the counter-party’s ability to perform its own recovery.
Regulatory Reporting and Communications
In the event of a disaster or a significant business interruption, Coastal Securities will make every effort to communicate with regulators utilizing any means of communication available. We recognize that it is critical that FINRA be notified of any business interruption of magnitude. Coastal has satisfied all regulatory requirements by supplying regulators with emergency contact information.
Coastal Securities, Inc. asserts that, to the best of its knowledge, all the information contained in this document is accurate. Further, Coastal Securities has developed a business continuity plan that meets regulatory requirements. In the event of a business interruption, Coastal Securities will make every effort to follow the plan as devised but acknowledges that the plan is highly dependent upon outside vendors and resources over which Coastal has no control. Further, Coastal does not guarantee that the plan can be fully implemented if a significant disaster results in massive destruction and/or loss of life.
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