business continuity plan jp morgan

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What Chase Bank has to Offer

Together, Citigroup, Wells Fargo, Bank of America and JP Morgan Chase make up the top four banks in America with Chase Bank being the largest. This multinational bank has over 5,100 branches with 16,000 ATMs, employs over 250,000 staff and operates in 100 countries. More and more customers are using this bank due to its convenience, wide variety of accounts and strong rewards program.

Nowadays banks are encouraging customers to use their online banking over going into the physical bank and Chase is no exception. Online banking can be useful in that it is convenient if you need to quickly check your balance, view statements or transfer funds. Chase online also offers customers the ability to view their statements going back up to seven years as well as be able to pay utility bills, mortgage, rent and/or credit cards. They will even send you an alert to prevent overdrafts.

Chase Payments

Chase has various payment services that can be used by customers such as the Chase Pay mobile app. If you are filling up your tank of gas and don’t have cash on you, simply scan your downloaded Chase Pay app and it will automatically be charged to your Chase account. They have also made it easy for you to use your account while surfing the web. If you come across a product you like and want to purchase when you check out there often is a Chase Pay option as well as a Chase Verify notification. By using the Chase Pay app, customers will receive special discounts and offers as well as bulk up their points.

Chase Accounts

Chase offers a variety of checking accounts, making it appealing to both high school and college students and owners of small, mid-size and large businesses. While their basic checking account covers general checking needs, there are accounts available that are aimed at helping you earn interest as well as receive benefits. Chase also has services for customers, which focus on helping them manage their mortgage, finance or refinance a car loan.

Chase Cards

While you may think credit cards are straightforward enough, JP Morgan Chase offers 25 different credit card customers can choose from, each catering towards various lifestyle and spending levels. If you are an individual who regularly enjoys treating yourself to a Starbucks coffee, then it might be worth looking into the Starbuck Rewards Card. If the Hyatt is your go-to hotel, then start using the Hyatt card where you can earn bonus points. For example, if you spend $2,000 within the first three months of opening the account, you will receive 40,000 bonus points and it only costs 5,000 points for a free night.

Those that travel frequently will want the Chase Sapphire Preferred Credit Card which allows customers to earn twice as many points on their travels and restaurant visits. If you spend $4,000 you will earn 50,0000 points which roughly equals $625 that can be used towards future traveling once redeemed. Or, if you often fly with United, check out the United Mileage Plus Explorer Card which gives you free bonus miles once a certain amount is spent.

Chase Points

Some customers enjoy redeeming Chase points and want to earn points as efficiently as possible. One of the best ways to do so is by taking advantage of their sign-up bonuses. In theory, you could have up to four personal cards and two business cards, and if you spend the required amount in the designated time to receive the sign-up bonuses, you could quickly build your points. Another way to gain points quickly is by referring a friend. They can help you earn up to as much as 5,000 points per reference and you can refer up to ten people. So start saving up and enjoy your gift cards, travels, and Amazon orders once you redeem your points.

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Business Continuity

Reviewed February 6, 2023

This policy documents the Firm’s plans with respect to Disaster Recovery, aka Business Continuity (“DR/BC”) with the primary goal of minimizing client service disruptions for the operating businesses of ICD Holdings, LLC (collectively “ICD” or the “Firm”), which include the following:

• Institutional Cash Distributors, LLC
• Institutional Cash Distributors Limited
• ICD Europa – Empresa de Investimento, S.A.
• Institutional Cash Distributors Technologies, LLC

The Firm’s plans will enable the Firm to quickly 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 our customers to transact business. In short, the DR/BC Policy is designed to permit the Firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. The DR/BC Policy addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank, and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

TECHNOLOGY SERVICES

ICD’s technical service functions and recovery can be managed without dependency on ICD offices. ICD uses commercially reasonable efforts to make ICD’s technical services available to clients 24 hours a day, 7 days a week, except for scheduled downtime and uncommon exceptions: internet or cloud service provider failure or delay, denial of service attack, DNS failure, or other circumstances beyond ICD reasonable control, including, but not limited to, fire, flood, or other climate events.  ICD’s technical services are architected for high availability, with full redundancy. All application data replicates bit by bit every second to a Disaster Recovery site for resiliency. 

ICD PERSONNEL – GLOBAL DESK SERVICES

The ICD Global Desk is comprised of four office locations:  London, UK; Lisbon, PT; Boston, MA (Cohasset, MA), and San Francisco Bay Area, CA.  Multiple office personnel locations allow for personnel redundancies in the event any single office location is rendered inoperable.  Global Desk personnel will regularly, and no less than annually, review emergency personal contact details so personnel may be called into support action during local non-business hours.  Additionally, at least annually the Global Desk will conduct a real-time office redundancy test to affirm action steps are appropriate for minimal client service disruption.  Details of Global Desk DR/BC plans can be found in numerous internal plan documents, including but not limited to call-contact tree and emergency details.

If after a significant business disruption ICD cannot be contacted as usual at +1.800.611.4423 and/or [email protected], you should call ICD’s alternate number +1.781.374.5152 in the U.S. or +44(0)207-968-4774 in the UK, e-mail [email protected], or visit http://icdportal.com where you can obtain additional information. If ICD cannot be accessed through those means, clients should contact our clearing firm, custody agent, or direct-investment channel for instructions on how to gain prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.

TRADING COUNTERPARTIES

JP Morgan Services (JPMS)

JPMS, backs up their 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, ICD has been advised by its clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 4 to 12 hours. Orders and requests for funds and securities could be delayed during this period.

In the event ICD is not available, clearing clients may contact JPMS at:

JP Morgan Services 383 Madison Ave Fl #23New York, NY 10179 +1.212.622.3076 (or [email protected])

MUFG-Union Bank (“MUFG-UB”)

In the event ICD is not available, custody clients may contact MUFG-UB at:

MUFG – Union Bank 350 California, 6th Floor San Francisco, CA 94104 Attention – Portal +1.877.578.7255 Client Service

Direct Funds

In the event ICD is not available, Direct-investment clients should contact their investment funds’ Transfer Agent service groups, in accordance with the funds’ prospectus or offering documents.

FOR MORE INFORMATION The ICD Business Continuity Plan is reviewed periodically and subject to modification without notice. The Business Continuity Plan disclosure is posted on our website at https://icdportal.com. A written copy of the summary of our Business Continuity Plan is provided to customers upon request. If you have questions about our Business Continuity Plan, you can contact us at +1.800.611.4423 and/or [email protected].

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Every Business Needs a Contingency Plan

The coronavirus situation reminds businesses everywhere that  employees, financial operations, supply chains and customer relations can all be affected. Fraudsters and cybercriminals also might see an opportunity to catch your business with its guard down. 

That’s why every business needs a plan to meet disruptions with clarity, confidence and relative calm. At Chase, we have our own resiliency protocols as well as tools and support to ensure your business is prepared. We’re here to help.

The Anatomy of a Plan

A good plan first identifies the most likely disruptions. Separating the probable from the possible helps you chart realistic tactics and achievable goals. Disruption comes in many forms:

• Are emergency supplies readily available? Will your vendors be affected?
• Do you have back up technology available? Will you be able to receive payments from customers?
• How will you manage through prolonged employee absence due to health concerns or illness? A good plan will answer a handful of core questions:

Regardless of disruption type, a good plan will answer a handful of core questions:

• What—systems and processes will likely be affected?
• Who—must be notified?   
• When—do specific actions need to be taken, in order of priority?
• Where—will your business operate?   
• How—will circumstances change the way employees do their work?

Getting Started

You’ve identified the likely disruptions. Depending on the identified possibilities your response will need to vary.  

Develop a continuity plan for each scenario. In case of potential data breach or malware attacks, notify Chase immediately, as well as your customers and vendors. In a situation where payment systems might be disrupted, have backup options in place if payments need to happen remotely. 

Ultimately, you want to protect employees, stabilize your supply chain and stay in close contact with customers. 

• Draw up scenario-specific health practices and evacuation plans. Know your protocol for securing facilities and data.
• Analyze and adjust cash-flow budgets so that you can pay employees and bills on time. Establish alternatives for paycheck distribution.
• Stay in close communication with existing vendors, financial institutions and external partners.
• Make it clear which suppliers, service providers and vendors you need to pay, including how much and by when. Consider keeping digital and printed copies of vendor-critical information.
• Prioritize transactions—time-sensitive, urgent, scheduled.
• Keep an eye on customer communication channels. Don’t overlook social media. 

Location, Location, Location  

For some businesses, a physical location is essential to ongoing operations. This might mean having alternate locations and backup facilities.

• Keep card readers and point-of-sale equipment clean and disinfected. Visit our payments support center for instructions.
• Can you rapidly shift accounting operations to a different location during a crisis? Be sure you have access to the tools you need to make time-sensitive payments, such as payroll and taxes.
• You might need Wi-Fi access or additional supplies and equipment, such as computers and deposit slips.
• Consider whether your business insurance provides coverage for a significant financial loss as the result of a closure or a disrupted supply chain.
• If your business is heavily dependent on a physical storefront, consider investing in your digital presence to help customers find you.
• How will workflow be affected at backup locations or for employees working from home? Can they get to important resources, such as banking IDs, passwords and accounts payable lists? Confirm that remote access and login credentials are current and that employees have remote access.

Communication

You’ve thought through the contingencies and documented your plan. To make it effective, you’ll need clear and thorough communication.

• What’s the emergency chain of command? Who takes on key responsibilities if those typically in charge are unable to do so? Set expectations. Name specific roles and actions.
• Assign a management team accountable for immediate response and employee safety.
• If your contingency site is being leased, communicate with the tenants about space allocation during an emergency. 
• Open lines of communication with those beyond your walls. Remember to include your customers, vendors and banking institutions. Public agencies and local services also need to know your plan. 
• Document and distribute all the above information.

Sharing and communicating your plan is vital, but don’t let it collect dust. Make preparedness part of your culture.

• Run training and Q&A sessions. Consider providing online resources or bringing in speakers to share experiences and best practices.
• Incentivize participation. For example, give a disruption-preparedness quiz and reward people for perfect scores.
• Practice your plan. Run through scripted crises in a tabletop simulation.
• Regularly update emergency and contact information. 

Post-Disruption

Even after a crisis has ended, you need to stay diligent. 

• Monitor banking services and payroll to ensure consistency.
• Stay alert. Businesses are more susceptible to cybercrime and fraud during sensitive times.
• Be empathetic. Consider employees’ emotional needs post-crisis. In some cases, you’ll need to be ready to offer access to support resources.

Focusing on preparedness and including everyone in the process helps your business minimize disruption, and it sends an important message: You care about your business, and you also care deeply about your customers.

Chase is committed to you and your business

We’re here for you when you need us, whether it’s providing best practices, professional consultation or business tools and resources. Reach out to your client service representative if you need assistance.

Here are some tips to help your business stay on the right track:

• Make sure we can get in touch with you if we need to confirm account information.
• Utilize ATMs. Download the mobile app so you have easy access to online banking from your phone. Use Chase QuickDeposit SM  to snap a picture of your checks and deposit them without hassle. 
• Send and receive money from virtually anyone you know and trust with Chase QuickPay® with Zelle®.
• Easily pay your Chase credit cards, loans and other bills by setting up recurring payments. See transactions, balances and important details like account and routing numbers, and transfer money between accounts without difficulty.
• Check out these  how-to videos .

Chase Mobile ®  app is available for select mobile devices. Enroll in Chase OnlineSM or on the Chase Mobile app. Message and data rates may apply. 

Chase QuickDepositSM is subject to deposit limits and funds are typically available by next business day. Deposit limits may change at any time. Other restrictions apply. See  Chase.com/QuickDeposit  or the Chase Mobile ®  app for limitations, terms, conditions and details. Chase Mobile app is available for select mobile devices. Chase QuickDeposit is compatible with iPhone and iPad devices with iOS 11.0 and above. For Android devices, we recommend a 4-megapixel rear-facing camera with auto focus for the best performance. Enroll on the Chase Mobile app. Message and data rates may apply.

Chase QuickPay ®  with Zelle ® : Enrollment in Chase Quickpay with Zelle is required. Both parties need a U.S. bank account; only one needs an eligible Chase account. Funds are typically made available in minutes when the recipient’s email address or U.S. mobile number is already enrolled with  Zelle  (go to  https://register.zellepay.com  to view participating banks. Select transactions could take up to 3 business days. Enroll on the Chase Mobile app or on Chase Online. Limitations may apply. Message and data rates may apply.

Zelle and the Zelle related marks are wholly owned by Early Warning Services, LLC and are used herein under license.

Chase Online Bill Pay: Must enroll in Chase Online Banking and activate Online Bill Pay. Certain restrictions and other limitations may apply.

IMPORTANT INFORMATION:

Chase, J.P. Morgan, and JPMorgan Chase are marketing names for certain businesses of JPMorgan Chase & Co. and its affiliates and subsidiaries worldwide (collectively, “JPMC,” “We,” “Our” or “Us,” as the context may require).The information in these materials is not advice on legal, tax, investment, accounting, regulatory, technology or other matters. You should always consult your own financial, legal, tax, accounting or similar advisors before entering into any agreement for our products or services. In no event shall JPMC or any of its directors, officers, employees or agents be liable for any use of, for any decision made or action taken in reliance upon or for any inaccuracies or errors in, or omissions from this information. JPMC assumes no responsibility or liability whatsoever to any person in respect of such matters, and nothing within this document shall amend or override the terms and conditions in the agreement(s) between JPMC and the Company.

J.P. Morgan will never send emails that require you to send account or personal information to us via public email or pop-up windows. View additional information on practices used by JPMC and how to safeguard your online activity at jpmorgan.com/info/jpmcpractices.

©2020 JPMorgan Chase & Co. All rights reserved. JPMorgan Chase Bank, N.A. Member FDIC. All services are subject to applicable laws and regulations and service terms. Not all products and services are available in all geographic areas. Eligibility for particular products and services is subject to final determination by J.P. Morgan Chase & Co. and or its affiliates.

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Chase Privacy Operations, Attention: Commercial Banking, PO Box 659752, San Antonio, Texas 78265-9752  

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Business Continuity Plan (BCP) 2023

I. Emergency Contact Persons  

Our Firm’s two emergency contact persons are: James St.Clair, President, (561) 703-6699, [email protected]; and Mark Ford, Chief Compliance Officer/AML Compliance Officer, (954) 304-3204, [email protected] . These names will be updated in the event of a material change, and our Executive Representative will review them at least annually.  

II. Firm Policy  

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. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.  

A. Significant Business Disruptions (SBDs)  

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. 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. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.  

B. Approval and Execution Authority  

James St.Clair, President, a registered principal, is responsible for approving the plan and for conducting the required annual review. Mark Ford or Megan Deihl has the authority to execute this BCP.  

C. Plan Location and Access  

Our Firm will maintain copies of its BCP, the annual reviews, and the changes that have been made to it for inspection. An electronic version of our BCP may be accessed using the “Business Continuity Plan” link located at the bottom of the home page of our website at www.viewtrade.com   . We also intend to utilize the BCP data repository offered by FINRA.  

III. Business Description  

Our Firm conducts business in equity, fixed income, and derivative securities. Our Firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders. All transactions are sent to our clearing firm, which further routes for execution, our orders, compare them, allocates them, clears and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our Firm services retail and institutional customers.  

Our clearing firm is:  

APEX Clearing Corporation (“APEX”), 350 N. St. Paul Street, Ste. 1300, Dallas, TX 75201, our contact person is Sheila Buchwald (214) 765-1593 email: sbuchwa[email protected]   or [email protected] .  

IV. Office Locations  

Our Firm has OSJ offices located in Florida and New Jersey.  

A. Florida Office  

Corporate and Local Branch Offices are located at 7280 W. Palmetto Park Road, Suite 310, Boca Raton, FL 33433. Its main telephone number is (561) 620-0306. Our employees may travel to that office by means of foot, car, or bus. We engage in Firm management, customer service, order taking, and entry at this location.  

B. New Jersey Office  

Our New Jersey Office is located at 525 Washington Blvd, 24 th Floor, Jersey City, NJ 07310. Its main telephone number is (201) 217-4422. Our employees may travel to that office by means of foot, car, subway, train, bus, or boat. We engage in customer service, order taking, and entry at this location.  

V. Alternative Physical Location(s) of Employees  

In the event of an SBD, we will move the appropriate staff from affected offices to the closest of our unaffected office locations. If none of our other office locations are available to receive staff, employees will work from home and connect to office facilities and/or each other via telephone, email and internet based Virtual Private Network technology.  

VI. Customers’ Access to Funds and Securities  

Our Firm does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm APEX. 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 clearing firm on their behalf, and if our Web access is available, our Firm will post on our Web site that customers may access their funds and securities by contacting APEX Customer Service.  

If SIPC determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books and records identifying customer accounts subject to SIPC regulation.  

VII. Data Back-Up and Recovery (Hard Copy and Electronic)  

Our Firm maintains its primary hard copy books and records at 7280 W. Palmetto Park Road, Ste. 310, Boca Raton, FL 33433. Megan Deihl, FINOP, (561) 620-0306, is responsible for the maintenance of these books and records. Our Firm maintains the following document types and forms that are not transmitted to our clearing firm:  

• new account documentation  
• all trading blotters and order memorandums  
• all financial documentation, including payables, receivables and payroll  
• all tax documentation and audited financials  

Our Firm maintains a backup of its electronic records within a safety deposit box. The financial data is backed up every quarter or if necessary, between quarters. These are stored locally in a safety deposit box at JP Morgan Chase Bank and Megan Deihl is responsible for the archiving of these records. The securities and client activity data is backed up on a monthly basis and this data is stored in Boca Raton on an external hard-drive. The Firm engages a third-party vendor ORBIS Systems to archive these records. Both are in the form of non-re-recordable CD-ROMS.  

The Firm backs up its electronic records monthly and stores them quarterly in a safe deposit box at JP Morgan Chase at 22191 Powerline Rd., Boca Raton, FL 33433.  

In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from APEX for those records archived by APEX. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location. For the loss of electronic records, we will physically recover the storage media from our back-up storage facility.  

VIII. Financial and Operational Assessments  

A. Operational Risk  

In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counterparties, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our internal email service, third party vendor email services, home telephone service and cell phone service. The necessary information to maintain these lines of communication have been compiled in a single spreadsheet and has been disseminated to each location. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).  

B. Financial and Credit Risk  

In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. We will contact our clearing firm and critical banks to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counterparties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our regulatory capital obligations. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including contact with all employees, the clearing firm and regulators  

IX. Mission Critical Systems  

Our Firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. More specifically, these systems include those provided by our clearing firm APEX. All account access, order transmittal, account inquiry and back office functions are accessed online via the APEX site, which is a web-based product and accessible from any internet connection.  

We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking and entry. Our clearing firms provide, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities.  

Our clearing firm contracts provide that our clearing firm will maintain a business continuity plan and the capacity to execute that plan. Our clearing firm has represented that they will advise us of any material changes to its plan that might affect our ability to maintain our business. A copy of their BCP may be found at (https://www.apexclearing.com/wp-content/uploads/2014/07/Apex-ClearingBusiness-Continuity-Plan.pdf). In the event our clearing firm executes their plan, it represents that it will notify us of such execution and provides us equal access to services as its other customers. If we reasonably determine that our clearing firm has not or cannot put their plan in place quickly enough to meet our needs or are otherwise unable to provide access to such services, our clearing firms represent that they will assist us in seeking services from an alternative source.  

Our clearing firm represents that they back up our records at out of region sites. Our clearing firms represent that they operate a back-up operating facility in a geographically separate area with the capability to conduct the same volume of business as their primary site. Our clearing firms have also confirmed the effectiveness of their back-up arrangements to recover from a wide scale disruption through a regular review and testing of their procedures.  

Recovery-time objectives provide concrete goals to plan for and test against. While their plans call for hard and fast deadlines that must be met in every emergency situation, various external factors surrounding a disruption, such as time of day, scope of disruption, and status of critical infrastructure—particularly telecommunications—can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption.  

A. Our Firm’s Mission Critical Systems  

Order Taking  

Currently, our Firm receives orders from customers via website and or telephone. During an SBD, either internal or external, we will continue to take orders through both of these methods, if 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. Customers will be informed of alternatives by either facsimile transmission, if available and practical, through the Firm’s telephone voice mail system and/or on the Firm’s website. If necessary, we will advise our customers to place orders directly with our clearing firms, using the Disaster Recovery numbers available to us.  

Order Entry  

The Firm enters orders through Orbis System’s (Pro-Trader and WebTrader) platform. In the event of an internal SBD, we will enter and send records to our clearing firms by the fastest alternative means available, which shall include, but not limited to, telephone, intranet wire service or cell phone. In the event of an external SBD, we will maintain the order in electronic or paper format and deliver the order to the clearing firms by the fastest means available when they resume operations. In addition, during an internal SBD, we may need to refer our customers to deal directly with our clearing firms for order entry.  

Order Execution  

In the event of an internal SBD, we would refer our customers to our clearing firms who will initiate their Disaster Recovery Procedures for the handling of our orders. In the event of an external SBD, we would immediately contact our clearing firm to determine the initiatives underway pursuant to their BCP and follow the direction given and to contact numbers, personnel contact, etc.

Other Services Currently Provided to Customers  

In addition to those services listed above in this section we also instruct our clearing firms as to the delivery of securities and cash on behalf of our clients as well as the processing of legal transfers. In the event of an internal SBD, we would refer our clients to contact our clearing firms Customer Service Departments directly if all means of communication with the Firm have failed. In the event of an external SBD, we would immediately contact our clearing firms to ascertain the availability of these services and follow their instructions pursuant to their BCP.

B. Mission Critical Systems Provided by Our Clearing Firms  

Our Firm relies, by contract, on our clearing firm to provide order execution, order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.  

X. Alternate Communications Between the Firm and Customers, Employees   and Regulators  

A. Customers  

We now communicate with our customers using the telephone (land-line and cell), fax, U.S. mail, and email at our Firm or at the other’s location. 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 have used in the past to communicate with the other party. For example, if we have communicated with a party by telephone but the land lines are unavailable, we will call them via cell phones and follow up where a record is needed with paper copy in the U.S. mail.

B. Employees  

We now communicate with our employees using the telephone, email, fax, and in person. 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 have used in the past to communicate with the other party. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers, fax numbers as well as known email addresses. The call tree will be divided by office and the designated principal in each location will contact one of the Firm’s Emergency Contact persons.   The person to invoke use of the call tree is either James St.Clair or Mark Ford.  

C. Regulators  

We are currently members of FINRA. We communicate with our regulators using the telephone, email, fax, U.S. mail, and in person. 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 have used in the past to communicate with the other party.

XI. Critical Business Constituents, Banks, and Counter-Parties  

A. Business constituents  

We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our Firm. Many of these vendors have their own Disaster Recovery Systems, Emergency Management Teams and Business Continuity Plans to help restore services to their customers in the event of a SBD, including, but limited to our telephone carriers and quote providers.

We have contacted our banks to determine if they can continue to provide the bank services that we will need in light of the internal or external SBD. The bank maintaining our operating account is:   JP Morgan Chase at 22191 Powerline Rd., Boca Raton, Fl 33433 (561)226-9890 and the contact is Kevis Rosario. In the event of an external SBD effecting the region, the JP Morgan Chase contact information is: 575 Washington Blvd., Jersey City, NJ 07310, (201) 595-5065. If our banks and other lenders are unable to provide any necessary financing, we will seek alternative financing immediately from officers and directors of the Firm.  

XII. Regulatory Reporting  

Our Firm is subject to regulation by FINRA, SEC and each state regulator in which the Firm is registered. We now file reports with our regulators utilizing online portals or using paper copies in the U.S. mail, and electronically using fax, e-mail, and the Internet. In the event of an SBD, we will check with the SEC, FINRA, and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

XIII. Disclosure of Business Continuity Plan  

We will provide in writing a BCP disclosure statement to customers on an annual basis. We also have the BCP disclosure statement posted on our website at www.viewtrade.com under Business Continuity. In addition, we will mail a copy to any customer upon request.  

XIV. Updates and Annual Review  

Our Firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our Firm will review this BCP annually, to modify it for any changes in our operations, structure, business, or location or those of our clearing firm.

XV. Senior Manager Approval  

I have approved this Business Continuity Plan as reasonably designed to enable our Firm to meet its obligations to customers in the event of an SBD.  

Signed: James St.Clair  

Title: President

Date: January 3, 2023

ViewTrade Holding Corporation

ViewTrade Holding Corporation (“ViewTrade”) is the parent company of Orbis Systems Inc and ViewTrade Securities Inc, each wholly owned subsidiaries of ViewTrade

Orbis Systems, Inc. Disclaimers

Technology Services are provided by Orbis Systems, Inc. (“Orbis”)

ViewTrade Securities, Inc. Disclaimers

Securities and brokerage services are provided through ViewTrade Securities, Inc. (“ViewTrade Securities”), a broker-dealer registered with the Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority ( FINRA ), SIPC , NYSE Arca, NASDAQ, CBOE Edge, CBOE BATS.

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INVESTMENTS: ARE NOT FDIC INSURED • MAY LOSE VALUE • ARE NOT BANK GUARANTEED

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