In accordance with FINRA Rule 4370, Guggenheim Investor Services, LLC (“GIS”) has developed a business continuity plan to assist the firm in appropriately responding to a significant business disruption (“SBD”) as promptly as possible under the prevailing conditions.
Business continuity is defined as the orderly return to normal business operations after an event has affected our facility. Our plan addresses data back up and recovery, mission critical systems, business impact (financial and operations) analysis, business resumption and crisis management communication. GIS periodically reviews and tests its business continuity plan to make sure that it remains accurate and effective.
In the event of a short term disruption, such as an evacuation of our facility, alternative recovery site arrangements have been made. Different courses of action will be pursued depending on the impacted site. To the extent necessary, critical staff will be relocated to another site.
In the event of a long term disruption, such as structural damage or denial of access to our office for a significant period of time, alternative staff recovery site arrangements exist and alternative technology recovery sites exist.
GIS is an introducing broker, and in accordance with SEC Rule 15c3-3(k)(2)(ii), clears all transactions with and for its clients on a fully disclosed basis with a clearing broker-dealer, and promptly transmits all client funds and securities to its clearing broker-dealer, J.P. Morgan Clearing Corp. (“JP Morgan”). Although it is our intention to remain in operation, in the event that a SBD prevents us from doing so, clients should contact JP Morgan directly at 212-552-1919 for liquidating orders, check and wire requests, and automated customer account transfers.
GIS will adhere to the procedures set forth in its business continuity plan and described in this disclosure statement to the extent commercially reasonable and practicable under prevailing circumstances. Although our plan is designed to address and respond to potential business disruptions, it is not possible to anticipate every scenario. In addition, disruptions, and the events that caused them, may vary significantly in size, scope, severity, duration and geographic location that could affect the firm’s recovery in vastly disparate ways. As a result, GIS reserves the right to respond to emergencies and SBDs in a situation-specific manner in which the firm deems prudent, in its sole discretion. Neither GIS’ business continuity plan nor this disclosure statement is a guarantee regarding the actions, performance or recovery of our systems or personnel in the event of a SBD.
Our business continuity plan and the disclosure statement are subject to modification at any time. We will post updates to the disclosure statement on our website or alternatively, updated hard copies may be obtained upon request by contacting Dina DiLorenzo at 212-901-9405 or by writing to Guggenheim Investor Services, LLC, Attn: Dina DiLorenzo, 330 Madison Avenue, New York, NY 10017.