Business Continuity Plan

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Business Continuity Plan

Cresap Inc. Emergency Procedures

** IMPORTANT CUSTOMER INSTRUCTIONS**

In the event of a communications failure or other emergency at one or more Cresap Inc. locations, please follow the following instructions.  Please call only if it is necessary to access your account.

  1. If you cannot reach your Cresap Inc. representative, contact our home office at 610-341-1320 or 1-800-760-3126.
  2. If you cannot reach our home office at the numbers above, you may contact one of the following individuals:

Marisa Welch
610-529-8871 (cell )
mgold@cresap.com

Mark Cresap
Executive Representative
610-529-8845 (cell)
mcresap@cresap.com

Richard Hess
610-453-5630 (cell)
rhess@cresap.com

  1. If you cannot reach any Cresap Inc. personnel, you may contact our clearing firm directly.Wells Fargo Clearing Services:  1-877 496 3221Wells Fargo Clearing holds your account and will provide access to your account if Cresap Inc. notifies them of an emergency.  There may be an interval time between our declaration of an emergency and Wells Fargo Clearing’s activation of emergency account access, so please be patient.You will be asked to verify your identity and you should, if possible, have a recent account statement available.  You may be limited to liquidation orders in certain classes of securities, or check processing.Please only contact Wells Fargo Clearing if it is absolutely necessary.

Emergency Contact Persons

Marisa Welch
610-254-2903 (office)
610-529-8871 (cell )
mgold@cresap.com (email)

Mark Cresap
Executive Representative
610-341-1327 (office)
610-529-8845 (cell)
mcresap@cresap.com

Richard Hess
610-341-1332 (office)
610-453-5630 (cell)
rhess@cresap.com

These names will be updated in the event of a material change and will be reviewed by our executive representative within 17 business days of the end of each quarter.

Firm Policy

Our firm’s policy is to safeguard essential customer information and firm financial information to permit continuity of operations in the event of business disruption.  Our plan will assure customers prompt access to their funds and securities.

  1. Our firm anticipates the possibility of 3 kinds of significant business disruption (SBD). One involves the loss of communication at any of our separate locations.  A second involves the loss of communication at our Radnor headquarters.  A third involves a catastrophic regional or national occurrence partially or completely disrupting communications systems.
  2. Mark Cresap, president, a registered principal, is responsible for approving the plan and conducting the regional annual review. Mark Cresap has the authority to execute this BCP.
  3. The firm will maintain copies of its BCP plan and evidence of annual reviews and any changes to this plan.  A copy is on file with the Philadelphia District FINRA Office.  An electronic copy is located on
    the firm’s website.

Business Description

Our firm operates on a fully disclosed basis with Wells Fargo Clearing Services LLC.  We do not hold customer funds or securities.  All transactions are entered at the trading desk at our Radnor headquarters and are then routed to our clearing firm for execution, comparison, allocation and settlement.  Our clearing firm carries our customer accounts, can provide to customers access to all account information and can provide directly to customers emergency transaction capabilities.  Wells Fargo Clearing’s main number is noted below.

Our clearing firm is Wells Fargo Clearing Services LLC, One North Jefferson Ave., St. Louis, MO 63103

Telephone: 1-877-496-3226

Website:  wellsfargoclearingservicesllc.com

Office Locations

Office Location #1
259 N Radnor-Chester Rd. Ste. 140
Radnor, PA 19087
610-341-1320
Order Taking
Order Entry

Office Location #2
117 E Grove St.
Clarks Summit, PA 18411
570-586-6320
Order Taking
Order Entry

Office Location #3
76 East State Street
Doylestown, PA 18901
215-828-3302
Order Taking
Order Entry

Office Location #4
10 S Bryn Mawr Ave
Bryn Mawr, PA 19010
610-581-4770
Order Taking
Order Entry

All employees commute to the above referenced locations by car.

Alternative Physical Locations

In the event of an SDC affecting any of our separate facilities, personnel will operate from our Radnor office or from their homes ( See exhibit 1 for telephone numbers).  A voicemail message will be recorded if possible, referring callers to the appropriate number (s).

In the event of an SBD affecting our Radnor office, firm principals (Gold, Hess, Cresap) will operate from their homes ( See Exhibit I for telephone numbers). A voicemail message will be recorded, if possible, referring callers to the appropriate number (s). The telecommunications provider for the Radnor office is different that the provider of wireless service for each emergency contact person.  Additionally, in the event emergency personnel are operating from home, the land-line provider at the homes of the three emergency contact listed is different from the above-referenced providers.

Customers Access to Funds and Securities

Our firm does not maintain custody of customer funds or securities.  All funds and securities are held by Wells Fargo Clearing Services, LLC.

In the event of an SBD, a voicemail message will be recorded if possible, instructing callers seeking access to funds or securities to contact their registered representative, who may contact our clearing firm directly.

If telephone communication is not possible, customers may refer to emergency instructions posted on our website, (this plan ) and available upon request concerning access to funds and securities.

Registered representatives will be instructed to contact all clients, to the extent possible, to advise them of emergency procedures in the event of an SBD.

Data Back-up and Recovery

Our firm maintains the primary set of books and records at 259 N Radnor-Chester Rd., Ste. 140, Radnor, PA, 19087.  Mark Cresap, president, (610-341-1320) is responsible for the maintenance of these books and records.  All essential documents other than new account forms are held by our clearing firm.

The firm maintains lists of client names and account numbers off-site so that essential transactions could be effected directly with our clearing firm by telephone or email from offsite.  The location, phone numbers, and the principals responsible for maintenance of these lists are as follows:

Marisa Welch, V.P.
7 Brookridge Dr.
Logan Twp., NJ 08085
610-529-8871 (cell)

Richard Hess, V.P.
582 Maddock Rd.
Springfield, PA 19064
610-453-5630 (cell)

These records will be updated semi-annually.

In addition, the firm stores all but the most recent hard copy records at Depot

Shops Self Storage, Paoli, PA.  This constitutes additional back-up as client names, account numbers and transaction records are available at this facility.  Marisa Gold, V.P., 610-341-1320, is responsible for maintenance of records at this facility.

All hard copy firm financial data is held at our Radnor office and is stored electronically on Quickbooks, which can be accessed from a remote location.  This information is backed-up electronically and by duplicate hard copy by our accountant.  The accountant’s name, address and telephone number is:

Mike Collins CPA
128 E State Street
Media, PA 19063
610-566-4760

Financial and Operational Assessments

Essentially, in the event of an SBD, the firm will operate through principals operating from remote locations.  Registered representatives will be instructed to contact clients, by whatever means, to inform them of emergency procedures.  Principals will either have full access to clearing firm information and systems through dialing into remote access servers, or will rely on client account numbers to communicate instructions to, or receive information from the clearing firm over the telephone.

Clients will have been given instruction to first contact their registered representative and, as an alternative, to contact remotely located principals.  A final option is for the client to contact the clearing firm directly.

The firm does not hold any allowable assets for net capital purposes in it’s headquarters or separate locations.  The firm’s allowable assets are essentially cash in the bank, cash on deposit at our clearing firm and commissions and fees receivable from our clearing firm.  Amounts of recent checks or payments not deducted from the bank balance are available from Quickbooks.  All information needed to perform a net capital computation would be available, with back-up form our accountant, from any remote location.

The firm does not rely upon any commercial lenders in the normal conduct of its business.

Mission Critical Systems

The following are the firm’s mission critical tasks and the entity responsible for executing them:

  1. Order taking – firm
  2. Order entry – firm
  3. Order execution – clearing firm
  4. Comparison – clearing firm
  5. Allocation – firm/clearing firm
  6. Clearance – clearing firm
  7. Settlement – clearing firm
  8. Maintenance of accounts – clearing firm
  9. Access to customer accounts – firm/clearing firm
  10. Delivery of funds and securities – firm/clearing firm

Of the tasks listed above, order taking and order entry are the primary responsibility of the firm.  As indicated in VIII above, the firm can perform these two functions from remote locations through dialing in to remote access servers.  Instructions regarding allocation and delivery of funds and securities may also be transmitted this way. Access to customer account information is also available.

If dial in capability to our clearing firm is somehow affected, instructions may be given and information obtained over telephone land lines, if available, or cellular phones.

The remaining functions are performed by our clearing firm.

All order taking information will be recorded on tickets as normal.  Since line printers will not provide execution information, this information will be obtained from the clearing firm, either over the order entry system or orally from a trader, and recorded on the ticket.

Alternate Communications Between the Firm and Customers, Employees and Regulators

Customers

Scenario 1. — Communications affected at separate location due to SBD.

If communications are not possible at a separate office, registered representatives will contact clients, by whatever means possible, to inform them of the situation.  If a recording may be made on the locations main number voicemail, that recording will advise customers as to ways to reach their registered representative or the Radnor office headquarters.  Customers will have been informed in writing and on our website as to various means of contacting the Radnor office.

Scenario 2. — Communications affected at the Radnor Office due to SBD.

If communications are affected at the Radnor Office, separate offices will be contacted immediately by whatever means necessary to inform them that principals will be moving to remote locations to continue operations.  Separate offices will have records of remote location land line and cell phone numbers.  Separate offices will be instructed to contact the clearing firm directly during the transition to remote locations.  If possible, a recording will be made on the main number informing customers that personnel are moving to remote locations and giving contact numbers of those locations and the clearing firm.  These emergency instructions will have been communicated to clients in writing and will be available on a posting on our website.

Scenario 3. — Communications affected at all locations

If communications are affected at all locations, registered representatives will be contacted on cell phones or at home phones and will be instructed that business will be conducted from the remote locations in accordance with #2 above.  All principals of the firm have a list of all registered representatives home, cell phone numbers and email addresses.

Employees

Each principal has both onsite and offsite, a list of all employee and registered representatives phone numbers and email addresses.  In the event of an SBD, each employee and registered representative will be contacted and given instructions.  Similarly, each employee and registered representative has all contact information for firm principals.

Regulators

We are currently members of FINRA. We communicate with the District Office by phone, Fax and email. In the event of an SBD, we would use any of these means to communicate a significant change in our operating procedure to the District.

In the event of a regional communications failure, the firm will attempt to contact the Washington FINRA office at 301-590-6500.

Banks

There are no relationships with any other institutions that are critical to our financial operations with respect to financing.  Our cash is held at the following institutions:

Bryn Mawr Trust
801 Lancaster Ave.
Bryn Mawr, PA 19010
Phone: 610-525-1700

PAIB Account
Wells Fargo Clearing Services, LLC
One North Jefferson Ave.
St. Louis, MO 63103
Phone:  866-786-4879

We have no relationships with critical counter-parties.

Regulatory Reporting

Our firm is subject to regulation by the SEC, FINRA , and Pennsylvania Securities Commission. Our regular reporting responsibility to the FINRA includes focus reports, which are filed electronically. In the event that an SBD affected our ability to file electronically, we would first attempt to fax the report to the District Office and if unable to do so, would mail a copy.

Hard copy audited financials are filed with the FINRA and states.  These documents would be filed as usual.

Disclosure of Business Continuity Plan

It is posted on our website and is available to customers upon request.

Updates and Annual Review

The BCP will be reviewed annually by Mark Cresap, President.  The BCP will be reviewed by December 31 to make any modifications that would be appropriate due to changes in location, structure, operations or clearing firm.

In addition, the plan will be updated to reflect any material changes.

Management Approval

I have approved the BCP as sufficient to allow the firm to fulfill its obligation to customers in the event of an SBD.

Signed: __________________________

Title:    __________________________

Date:    ___________________________

Updated 05/11/2018