Capital Markets
Business Continuity Planning
Business
continuity planning (“BCP”)
Our firm’s policy is to respond to a future Significant Business Disruption
(“SBD") by safeguarding employees’ lives and firm property,
making a financial and operational assessment, quickly recovering and resuming
operations, protecting all of the firm’s books and records, and allowing
our customers to transact business. In the event that we determine we are unable
to continue our business, we will assure customers prompt access to any funds
or securities due to them.
We have developed a Business Continuity Plan that details the efforts
we will make to address any SBD, whether it is internal or external
in nature. This document summarizes the plan and the actions we will
take to address any SBD quickly and efficiently.
Business continuity contacts
In the event of an SBD, all of our employees will be immediately notified by one of our SBD Crisis Response Team members. The SBD Crisis Response Team Members are Ron Iervolino, Rob Holmen, George Tilghman and David Conrod. The team will be activated once an SBD has been declared.
Plan testing
The Plan will be tested at least semi-annually to ensure a state of readiness.
The testing may include “live” testing that will employ the use
of a disaster recovery site or it may be a paper-based test. The testing
may be pre-announced or called without notice, at the discretion of the company’s
management. Training will be implemented as necessary throughout the year
to ensure compliance with the plan elements.
SBD scenarios
Once a potential SBD occurs, the Crisis Response Team and others will immediately
set the plan in action. First, the safety of all employees will be considered.
Second, data will be gathered on the SBD and the effects on systems and other
resources. Finally, a decision will be made on which type of response will
be employed.
A variety of scenarios have been considered in the development of
the BCP. To highlight several of these, the following chart illustrates
the severity of the SBD and the planned response, including response
and resumption objectives.
| SBD scenario |
Temporary Internal SBD
(Loss of power, fire, bomb threat, HVAC failure, etc.) |
Internal SBD (loss of power,
phone, data/internet service building-wide) |
External SBD (loss of power,
phone, data/internet service — regional) |
| Duration |
< 4 hours |
> 4 hours |
> 4 hours |
| Characteristics |
Internal systems outage,
forced to evacuate building for less than 4 hours. |
Internal systems outage,
forced to evacuate building for indeterminate amount of time. |
Due to external factors:
systems outage, power outage, forced to evacuate building for indeterminate
amount of time. |
| Effect |
Communication with customers,
clearing firm, vendors, banks limited to external systems (cell
phones, blackberry’s, outside communication sources). |
Communication with customers,
clearing firm, vendors, banks limited to external systems (cell
phones, blackberry’s, outside communication sources). |
Communication with customers,
clearing firm, vendors, banks limited to external systems (cell
phones, blackberry’s, outside communication sources). |
| Response |
Level 3 Response: Send
abbreviated team to DR site to resume operations. All other employees
will be instructed accordingly. |
Level 2 Response: Resume
operations from DR site as soon as possible. All mission critical
employees will report to DR site, others will work from alternate
office sites. |
Level 1 Response: Resume
operations from DR site as soon as possible. Notify customers
and other key contacts of status. All mission critical
employees will report to DR site, others will work from alternate
office sites. |
| Systems Response |
Use NY based back-up systems |
Use NY or Chicago based
back-up systems; implement alt. telecommunications plan |
Use NY or Chicago based
back-up systems; implement alt. telecommunications plan |
| Response Time |
60 - 90 minutes |
60 - 90 minutes |
60 - 90 minutes |
| Resumption Time |
90 - 120 minutes |
90 - 120 minutes |
90 minutes - 4 hours |
IT backup and storage
As part of normal operations, all systems and data stored on the network are
being backed up on tapes every evening. These tapes are stored on 20-day
rotations and a copy is stored off site every week in a storage facility
managed by an outside storage company.
Business continuity
Guggenheim Capital Markets is committed to responding to an SBD efficiently
and effectively in order to resume business as normal as quickly as possible.
We will do everything in our power to communicate with our customers, counterparties
and other mission critical partners, the status of our operations as frequently
as we deem necessary.
This plan is subject to modification. If the plan
is modified, an updated summary will be promptly posted on our Web
site. Customers may alternatively obtain updated summaries by requesting
a written copy by mail.
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