Steben & Company, Inc.
Business Continuity Plan (BCP) Customer Summary
SCI is providing this document to
inform you of its ability to respond to certain business disruptions.
Consistent with its Business Continuity Plan, SCI maintains back-up facilities in
geographic locations separate from its primary facilities. Using these back-up
facilities, the Firm intends to continue its business in the event of a
significant business disruption. Nevertheless, there are some disruptions that
may render the Firm unable to continue business. Under such circumstances, SCI
will try to ensure that Clients will be able to obtain information about and
access to their funds invested in SCI managed futures funds, as well as
material developments affecting the SCI managed futures funds.
Clients, however, should note that these responses are subject to modification
and depending on the severity of a specific event SCI cannot guarantee that it
will follow the stated course of action. To receive up-to-date information
during a Significant Business Disruption (SBD), Clients may call the Firm’s
emergency telephone number at 240-683-1404 or try accessing our website at www.steben.com.
Our firm’s policy is to respond to a 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 continue transacting business.
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building or loss of electricity in our local grid. Internal SBDs may last an hour to two days. This disruption may be caused by physical damage, technology problems, or an inability to have personnel arrive at the office. Because the home office is more critical to the Firm’s operations, SCI’s ability to resume business following a disruption to a specific building depends on the building affected. If the location is unusable, SCI has duplicative systems that will be run from a separate building. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location. The Firm expects the transfer of operations to be less than one day.
External SBDs prevent the
operation of the securities markets or a number of firms, such as a terrorist
attack, a city flood, or a wide-scale, regional disruption. External SBDs are
likely to persist for several days to perhaps several weeks. In the event that
there is a SBD that affects the business district, city, or region where any of
the Firm’s primary systems are located, SCI will transfer its operations to
back-up facilities. If our primary site is inoperable, we will continue
operations from our back-up site or an alternate location. In this process, Customers
may experience a substantial delay in reaching the Firm due to increased
telephone calls, technology delays, or other difficulties arising from the
transfer of operations.
Our firm does not maintain custody of customers’ funds or securities. Interests in commodity pools operated by SCI are not issued in certificate form. SCI maintains records of the ownerships interests of limited partners in each of the pools that it operates. Assets of those pools are in the custody of the pool’s respective futures commission merchants, cash management broker or banks or their affiliates which are in separate and distinct geographical locations. Customer funds are not held directly by SCI. In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our selling agents, futures commission merchants, cash management broker or banks or their affiliates on their behalf with respect to their investments in the limited partnerships. Our firm will make this information available to customers through its disclosure policy.
Our firm maintains its primary
hard copy books and records and its electronic records at its office located at
In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our backed-up electronic storage media or contact our selling agents, futures commission merchants, cash management brokers or banks or their affiliates. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up site.
If you have questions about our BCP, you can contact us at 240-631-9808 or info@steben.com.