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Higgins Capital Management, Inc. (the” Firm”) is committed to safeguarding the interests of our clients and customers in the event of an emergency or significant business disruption. This Business Continuity Plan Disclosure (the “BCP”) summarizes Higgins Capital Management, Inc.’s effort to mitigate risks inherent with unforeseen business interruptions. The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers even in the event of an emergency or significant business disruption. This BCP is intended to comply with the rules promulgated by the Financial Industry Regulatory Authority (“FINRA”).

Overview

Higgins Capital Management, Inc. maintains two facilities to house the backbone of our trading, sales, operations and information technology. These two facilities are located far enough apart to diminish risks posed by local disruptions. This separation is a key element of the Firm’s overall business continuity strategy. This separation allows us to plan for events at each location individually, since no one event should effect more than a single location simultaneously. The benefit of having only one site in each location means our response to an event will be the same whether the event is a firm-only business disruption, a disruption to a single building, a disruption to a business district or a city-wide business disruption.

Communication with Our Employees in the Event of a Disruption

 The safety and well-being of our employees is a vital concern. I n the event of an emergency or significant business disruption, the Firm will communicate with its employees in several different ways. We use direct targeted outreach. All information such as office closures and operating hours will be immediately communicated via telephone and email. Likewise, senior managers will be contacted directly via telephone and email.

Redundancy of Mission Critical Information Technology Systems

Higgins Capital Management, Inc.’s primary information technology processing and backup site that provides the redundancy required to protect the firm’s books and records, balance sheet and capital, and provide business continuity and client protection. The recovery capability for certain of the firm’s mission critical processing capabilities is achieved through the use of data backup redundancy. Unlike many shared facility that allocate computer capacity to several different clients on a first-come-first-serve basis, Higgins Capital Management, Inc. owns fully dedicated backup equipment located at our backup facility. Other mission critical systems are protected by the use of redundant technology located at our disaster recovery center. Recovery times for mission critical systems range between real time recovery and 4 to 12 hours.

Back-Up Trading, Sales and Operations Site

Higgins Capital Management, Inc. maintains a backup operations center located approximately 10 miles from our headquarters. In the event that we are unable to access our primary facility, it may be necessary to relocate certain personnel to the backup site. The backup facility is a “hot site.” In other words, the site is fully operational at all times. It is equipped with workstations that have redundant computer network connectivity, telephones, printers, fax machines, market data feeds and all the other specialty equipment necessary for trading and operations. The backup trading positions are periodically checked to ensure that they are equipped with updated software and trading applications. The functionality of the backup facility is routinely tested by sales, trading and operations personnel.

Disclaimer

The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers even in the event of an emergency or significant business disruption; however it is not infallible.  The plan is designed to work in many different emergency situations; but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption. Furthermore, although we are confident in our own preparedness, Higgins Capital Management, Inc. has no control over the various entities that we must rely upon in the event of an emergency.  Our business continuity plans are tested periodically to ensure readiness; yet such tests may not be able to replicate the actual conditions we experience in a real emergency.  This BCP is subject to change without notice.  In the event this BCP is modified, the updated document will be posted on the Higgins Capital Management website.  Alternatively, customers may obtain an updated hard copy BCP upon request.  The information contained in this disclosure is provided by Higgins Capital Management, Inc. for informational purposes only.  Nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any customer agreement between you and Higgins Capital Management, Inc.

In the event HCM cannot be contacted, clients can call the clearing firm direct for account inquiries:

Correspondent Relations Service Manager, Client Relations
US Brokerage Operations
RBC Capital Markets, LLC
T. 612-607-8386 or 866-506-8595
F. 866-861-3452
510 Marquette Avenue South - M12
Minneapolis, MN 55402


Any one of the Correspondent Relations Service Managers at 612-607-8386 will be able to help.

 

BUSINESS CONTINUITY PLAN

 

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