Steben Business Continuity Plan (BCP)

Summary

Steben has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – After a significant business disruption you will be able to contact us as you would by phone at 240-631-7600; fax at 240-631-9595; or email at info@steben.com.  Since the phone numbers, fax numbers and email addresses are backed up at both primary and backup sites these contact will work even if Steben’s primary site is unavailable.

Our Business Continuity Plan – Steben’s plan is to recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing customers to transact business. In short, the business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. 

Our business continuity plan addresses: data backup and recovery; mission critical systems; financial and operational assessments with customers, employees, and regulators; potential alternate physical locations for employees; critical suppliers, bank and counter-parties; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firms back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments as soon as practical. Your orders and requests for funds and securities could be delayed during this period. 

 

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within a 24 hour period. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within a 24-48 hour period. In either situation, we plan to continue in business, and notify our customers how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

 

For more information – If you have questions about our business continuity planning, you can contact us at 240-631-7600 or email us at info@steben.com