In the event of an Act of God or some other type of disaster that results in the severe damage to the firm’s main office, all customer account information and trading access is available at the firm’s clearing brokers (FCM’s). As such, customers are always able to obtain information on their account, regardless of the customer’s inability to contact the firm directly.
All network and software information located at the firm’s main office and our internal network houses customer information as well as firm’s financial information. This system is maintained by contract through an independent consultant, Lan IT Solutions, in Orlando, Florida. Lan IT Solutions maintains our system data on backup server located offsite to which our main server is backed up daily. The temporary back up facility for EFT is the office of Lan IT Solutions at 322 East Central Blvd, #515, Orlando, Florida 32801 which is on a different power grid with different telecommunication vendors. All AP’s will be notified to report to the temporary backup facility until a more permanent office location can be set up or the main office is restored.
Lan IT Solutions stores off-site electronic files to include all company books and records (this is inclusive of all hard copies and electronic copies of records of EFT). EFT scans and electronically stores all documents which is backed up daily and stored by Lan IT Solutions. EFT disaster recovery off-site location will maintain the necessary equipment to continue operations. The following will be maintained at this off-site location.
- Copies of account files are stored electronically
- Computer and other equipment used for order taking
- Company telephones will be forwarded to this location
All customer account information is also backed up and stored at EFT’s main office. All AP’s will be contacted as soon as reasonably possible to discuss relocation to the back up facility.
The firm’s trading systems are connected to the firm’s clearing brokers via the Internet. As such, an interruption in the firm’s internet connections could disrupt the firm’s electronic trading capabilities. With this in mind, the firm has set up a dedicated T1 line exclusive for trading data and execution. As such, in the unlikely occurrence of one of these Internet connections failing, the second ISP connection would maintain the required connection.
In the event of the firm’s telephone network system being interrupted, the firm’s associated persons all maintain cellular phones, and would be able to contact customers. In the situation where the firm’s Manager is unavailable to answer questions related to the current status of the firm’s operations, the firm lists the emergency contact information of the firm’s Executive Officer and APs on the website.
The firm will contact the NFA and CFTC in the event of a disaster at the firm. These procedures will be reviewed on an annual basis, at the same time as the annual certified audit by the firm’s public accountant.