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.
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.
Our firm operates on a fully disclosed basis with First Clearing 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. First Clearing’s main number is noted below.
Our clearing firm is First Clearing LLC, One North Jefferson Ave., St. Louis, MO 63103
Office Location #1
259 N Radnor-Chester Rd. Ste. 140
Radnor, PA 19087
Office Location #2
117 E Grove St.
Clarks Summit, PA 18411
Office Location #3
76 East State Street
Doylestown, PA 18901
Office Location #4
10 S Bryn Mawr Ave
Bryn Mawr, PA 19010
All employees commute to the above referenced locations by car.
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.
Our firm does not maintain custody of customer funds or securities. All funds and securities are held by First Clearing, 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.
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 Gold, V.P.
7 Brookridge Dr.
Logan Twp., NJ 08085
Richard Hess, V.P.
582 Maddock Rd.
Springfield, PA 19064
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
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.
The following are the firm’s mission critical tasks and the entity responsible for executing them:
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.
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 an 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.
Each principal has both on site 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.
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.
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
First Clearing, LLC
One North Jefferson Ave.
St. Louis, MO 63103
We have no relationships with critical counter-parties.
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.
It is posted on our website and is available to customers upon request.
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.
I have approved the BCP as sufficient to allow the firm to fulfill its obligation to customers in the event of an SBD.