Business Continuity Plan Summary
Introduction
Coastal Securities has developed a Business Continuity 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.
Business Continuity
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 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
- porting of phone numbers to our DR Facility for employees
- the management of the building where Coastal’s main office is located has emergency contact information that has been disseminated to all employees
Alternate Locations
All key personnel and their back ups have been equipped with laptop computers and/or Blackberry
mobile devices in order to continue communications from remote locations. Certain personnel
may establish a central command post in Coastal’s Austin 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 for business resumption, including those involving
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 facsimileto (201) 413-5368 or by postal service as follows: Pershing LLC,
P.O.Box 2065, Jersey City, NJ 07303-2063. 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
(http://www.pershing.com/customer_support.html)
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 transactional data, critical applications and customer account
information in a geographically dispersed, redundant DR processing facility located 160 miles outside
the city of Houston. In addition, we have the ability to relocate associates and resume business
functions at Coastal’s alternate business continuity site. The DR facility is available immediately at
time of disaster (ATOD) to support the initiation of recovery effort. The DR facility is a
state-of-the-art, hardened facility with capabilities such as separate power grids, dual power feeds
from redundant substations, generator back up, and secure facility access. This PCI Level 1 and
SAS 70 Level 2 compliant facility maintains the highest levels of security with 24/7/365 monitoring and
surveillance from on-site personnel.
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, 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.
Disclaimer
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.