Business Continuity Statement
Regular evacuation drills
and emergency preparedness meetings, led by
trained security professionals are held by our
facilities to ensure employee safety in the
unlikely event of an emergency.
Destruction of the
Firm's Principal Place of Business
In event that the principal
place of business is destroyed or damaged to
a point where it cannot be utilized, the Contact
Manager will contact each employee and provide
instructions for reporting to work. Allen C.
Ewing & Co. has two primary locations in
Jacksonville, FL and Charlotte, NC. These separate
sites provide backup for most critical functions.
Notification to the
After an emergency has
been declared, the Disaster Team Leader will
notify the proper regulatory authorities and
the Designated NASD Examiner of the nature of
the emergency, the temporary location of the
firm and any other information as required by
law. Additionally, the Contact Manager will
notify the local public utilities, telephone
company, post office and any other vendor as
Regardless of the extent
or scope of destruction, this plan is designed
to ensure that Allen C. Ewing & Co. can
continue to meet all regulatory requirements.
ACE will be able to continue all regulatory
reporting through our secondary location or
alternate work site.
Equipment / Hardware
The Contact Manager will maintain
a list of all equipment, hardware and software,
used by the firm. The list shall contain the
item, the serial number, the manufacturers and
serial/registration number. The Contact Manager
will also notify the firm's insurance company
of any damage.
A secure back-up system
has been created on our server, which will enable
us to keep a weekly back-up of all records on
the server in an offsite location in case of
Mission Critical Systems
Mission critical systems
include server, FBSI and Streetscape access,
of which all can be retrieved via a secure online
VPN connection from any offsite location.
and Client Trading Records
Hard copies and electronic
original client agreements, contracts, profiles,
and other documentation related to each client
as well as trading records, brokerage statements
and confirmations are maintained at the principal
place of business for the appropriate time that
is required by law. After such time the documentation
may be moved offsite to a secure facility where
both client and firm confidentially can be assured.
Copies of pertinent
client information can be requested from our
clearing firm National Financial Services, LLC
Semi-Annually, the a
designated principal will review these Business
Continuity plans pertaining to our clients records
to assure that these records will be adequately
maintained in the event of a disaster or emergency.
Upon the declaration of an
emergency, where normal lines of communication
are no longer available, all personnel will
attempt to communicate with their clients via
any means available. Customer information can
be accessed offsite at all times via National
Financial, LLC's online connection, Streetscape.
Each registered representative should also maintain
a list of their current clients, which includes
all known contact numbers (home, work, cell
phone, pager number and e-mail addresses). If
the registered representative is unable to contact
their clients, they shall report the situation
to the firm's principal. Upon notification,
the firm's principal will attempt to contact
the client. A log will be kept of each attempt
and each client contacted.
Notifications will include
the length of outage, instructions for contacting
ACE and National Financial Services, LLC and
any other pertinent information.
When contacting the
local telephone service, a message will be set
up to redirect all clients to the appropriate
Preparedness of Vendors
Allen C. Ewing & Co. will
request copies from all critical vendors and
custodians of their Business Continuity Plan
or a confirmation from such vendors or custodian
that a plan exists, is current and has been
tested. A log will be maintained of all vendors
and custodians and their emergency contact numbers.
Such list shall be reviewed annually.
Vendors and custodian
preparedness will be discussed amongst the principals
of the firm in the event that they are not satisfied
that any such vendor or custodian is adequately
prepared for an emergency. The vendor or custodian
should also be contacted to discuss any concerns
relative to the plan that he/she may have. Such
conversations will be documented and kept in
a vendor and custodian file.
and Credit Risk Assessment
Due to the nature and size
of our business, there will be minimal impact
if one of our offices is affected by an unlikely
disaster. Operations can resume in our secondary
office location, customer assets are securely
held by our introducing firm, National Financial
Services, LLC and there is appropriate insurance
coverage to assist ACE in the reestablishment
of its office.
Allen C. Ewing & Co. will
report to the NASD, via such electronic or other
means as the NASD may require, prescribed emergency
contact information. The emergency contact information
will include the designation of two emergency
contact persons, which will be a part of senior
management and a registered principal.
Allen C. Ewing &
Co. will promptly update all emergency contact
information, via such electronic or other means
as the NASD may require, in the event of material
change. Allen C. Ewing & Co. will also update
its emergency contact information, including
the designation of two emergency contact persons,
within 17 business days after the end of each
calendar quarter to ensure the information's
accuracy. The Executive Representative, or his
or her designee, which designation must be in
writing, must conduct such review and update.
Notification to Clients
of the Firms Business Continuity Policies
Allen C. Ewing & Co. will
notify each client at account opening, and annually
of the disaster preparedness plans. The notification
will contain contact numbers (such as telephone
numbers, Internet address, pager numbers, etc.)
that may be used by the client to reach someone
at Ewing in case of an emergency.
If key personnel or
Allen C. Ewing & Co. are unable to carry
out their usual duties, the notification will
contain the telephone number and a contact person
at the custodian firm that will assist the client
and assure prompt access to their securities
and funds in the event of an emergency.
Charlotte Office (704) 332-2032
National Financial Services, LLC (617) 563-5977