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Ladenburg Thalmann & Co. Inc. (“Ladenburg”) has
implemented a business continuity plan (“BCP”) in the event that a
function deemed critical to Ladenburg’s ongoing business operations
fails. The plan will assist Ladenburg to eliminate and minimize any
business interruptions as a result of an unexpected disaster. The plan
as well as the plan of our clearing firm, National Financial Services
LLC, a Fidelity Investments company, has been tested at various times.
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 transact business.
Ladenburg has established procedures in the event of a disaster.
The plan will continually be updated during the disaster period until a
full resolve is achieved.
With locations in various cities within New York as well as various
other states around the country, Ladenburg has the ability to
strategically execute the plan.
Any informational updates in the event of a disaster will be available
to our clients and our employees via our web-site (www.ladenburg.com).
The disclosure of our BCP plan summary posted on our web-site is subject
to modification and any updates will be promptly posted. Customers may
alternatively obtain updated summaries by requesting a written copy by
mail.
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. In the case of internal SBDs, we expect
recovery, with any required alternative arrangements in place, as
quickly as possible but in any event within a few hours. 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. The timing of our recovery after an external SBD relies more
heavily on other organizations and systems, especially on the
capabilities of our clearing firm, but in any event is expected to be
less than a day.
Our firm does not maintain custody of customers’ funds or securities,
which are maintained by our clearing firm. In the unlikely event that we
determine we are unable to continue our business as a result of an SBD,
we will assure customers prompt access to their funds and securities
through our clearing firm. In the event of an internal or external SBD,
we will continue to take orders through any of the methods that are
available and reliable, and in addition, as communications permit, we
will inform our customers when communications become available to tell
them what alternatives they have to send their orders to us.
In the event of an SBD, we will assess which means of communication are
still available to us, and use the means closest in speed and form
(written or oral) to the means that we currently use to communicate with
the other party. Also, incoming telephone calls from customers may be
routed away from an office experiencing an SBD to an unaffected office.
Our firm maintains primary hard copy books and records and electronic
records, and for most items back-up hard copy books and records. The
firm backs up its electronic records daily. In the event of an internal
or external SBD that causes the loss of our paper records, we will
physically recover them from our back-up site or make other appropriate
arrangements.
We disclose in writing a summary of our BCP to customers at account
opening. We also post the summary on our Web site and mail it to
customers upon request.
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