Securities industry regulations require that broker-dealers inform their clients of their plans to address the possibility of an unplanned significant business disruption (“SBD”) resulting from, among other things, extraordinary events such as power outages, building evacuations, natural disasters, acts of terrorism or other catastrophes. Industrial and Commercial Bank of China Financial Services, LLC (“ICBCFS”) has a comprehensive business continuity plan (“BCP”), which we periodically review, update, and test.
Generally, we can conduct our business at multiple locations. Our BCP is designed so that, if one of our locations or means of communication experiences a SBD, critical business functions, including order acceptance, entry, and execution, can be carried out at an alternate location. In the event that a SBD impacts a particular location, we will utilize our disaster recovery site so that our clients can continue to conduct business with minimal, if any, interruption.
ICBCFS is located in New York, NY and maintains a dedicated off premises disaster recovery site. Mission critical systems, core infrastructure, and data in our New York data center facility are duplicated (i.e., mirrored) at this alternate site. In addition, critical network connectivity to third-party partners, vendors, and clients is maintained at the alternate site.
All data systems deployed at our primary data center in New York, NY are protected by Universal Power Supply (UPS) and back-up diesel power generators, which are tested monthly. Daily back-up of data is processed and secured to our alternate site by qualified, professional data recovery storage providers. A secondary copy of daily data backup media is also retained at our main office in New York, NY to comply with record retention requirements.
ICBCFS’s business continuity processes are managed and overseen by dedicated, experienced staff within our Technology, Operations and Client Services departments by Senior Management. There are many different events that are factored into our disaster recovery protocols:
In the event of an office closure or SBD, ICBCFS has a designated employee rendezvous location to expedite employee relocation. Our BCP provides specific direction on where critical personnel will work in the event of a SBD. A full system test is performed at our alternate site to ensure proper functionality. In addition to this routine testing, employees work at our alternate site on a regular basis to assess the functionality of each system maintained at the site under conditions where the market are operating at full capacity.
Our BCP includes detailed tasks covering all facets for disaster recovery and site functionality. Each task is comprised of several sections: infrastructure network connectivity, application delivery, voice broadcast systems, phone, recorders and fax, printing, remote access, market data, back-up services, and revert actions.