BUSINESS CONTINUITY PLAN

This business continuity plan is written for the benefit of my customers, my prospects, my suspects, and lastly, my regulator, whose template will be at the very end.

Since we are a two man shop, the safety and health of the Profitabull is of paramount importance, both to the firm and it’s customers.  Bullish Bob Bagley is 71 and on Medicare.  That does not mean I am going to retire or am even thinking about it.  My pace-setter and Broker/Dealer hero is Bill Burnside of William C. Burnside & Company, Inc.  He is 85 and is a great torch bearer for me!  But Heaven issued that margin call, and Bill had to meet it.  And Andy is 73, so read on, out of necessity!

We have had to sell our beloved Dodge truck to a young man, 16 years old.  He had really good tires on that truck and we wish him even better experiences with it than we had.  We drive a 2001 Mercedes E-320 Station Wagon.  It seems to be built like a tank, but gets great gas mileage.  Our tires are smaller too, we are on 215.55.16, but we buy tires to take the heaviest load we can and still do 120 mph rating on the tire.  We are getting to old to drive that fast for long, but we want to be able to do it in case our regulator is chasing us.  This wagon is generally parked by a brick wall, which protects the principal when he gets out of the truck and walks 20’ feet to a 48” high 1”X6” redwood gate mounted on 4X4 posts set in concrete.  The gate is of a double swinging nature with about 22” to each side.

The principle then walks another 30’ under a 25’+ tall yaupon holly to 17 concrete aggregate steps 36” wide with steel handrails on both sides, which takes him to the second floor of 2535 A Cedar While he walks under a 25’+ tall yaupon holly for about 12’ and all 17 steps, he can be shit on by the birds.  We have never discovered a way to protect him from them.  The “A” stands for “Above” or “Angel.”  The principal uses the same method of entry as we were audited for in our Y2K audit.  Our landlord is Bob Spurgin, who can be reached around the corner of the building at 2521 Cedar Springs Road.  His telephone # is 214-871-3322.  We have a month to month rental handshake agreement, which so far, is 28 years old.  Older than a lot of marriages.

We then proceed to our office.  In it we are currently running an ASUS i5 computer, with 2 ASUS 24 monitor that refresh at a rate of 1ms.  This is because my eyes are older and the flashing of the lights gives me a headache at the slower speeds.  The speeds of the baud and drives and rams are such that it doesn’t seem to matter anymore.  It will double again before I can hit the enter key anyway.  We have dramatically upgraded our software systems.  We are now on Windows 7 Professional, with Office 365 and the Microsoft Cloud.  We are keyboard driven and use a Logitech low end gaming keyboard that is backlighted for my eyes, and it is model G710+.  We also use the Logitech thumb ball mouse to save having to move our shoulders so much.  We have also turned to an IT guy.  Trevor Tinsman with TechMedix can be reached at 972.424.0780, http://techmedixinc.com/  and I highly recommend him.  He also is the IT guy for my wife’s business and keeps us both running come what may.  If he is out of state, he still logs into to see my screens and fixes any problem I can create.  Ironically, he is the son of the receptionist that I worked with when I was with Eppler, Guerin and Turner in the 70’s & 80’s.  She now delights in being a grandmother.  All of this for now is serviced by the internet cable of Time Warner, for which I can’t say anyting.  We are waiting for the Wifi of Google to come to Dallas as it seems the wifi is going to replace the fiber cable rapidly.  We are serviced by the lowest cost electric provider that we can find: http://gpltexas.org/pdfs/Rate%20Files/8-4-2016%20Residential%20Rate%20Comparison%20Graph.pdf  This website will assist you in finding the lowest rates in Texas.  I generally choose the one 3rd from the lowest and so far, no problems yet.

Our phone system is voip via http://www.phonepower.com/voiphome.aspx  and we have been with these folks for years and they give great service and even better prices.  We recommend them too.  They drive our Panasonic 2 line DECT 6.0 phone with a handset with a headset.

Our isp server www.inmotionhosting.com, 888.3214678 and our website is serviced by Word Press.

Our secondary backup location is guarded by Apex Protection Service LLC.  We also have locked doors, by Baldwin Lockset hardware.  We utilize a room of the house for all of my business dealings, but this room is shared with my wife, as Texas is a community property state.  Our transportation of material takes place via the Office 365 cloud connections and our thumb drives we carry as a belt and suspenders case.

 

Our CPA is Philip V. George, 214.385.5150, 1842 FM 1566 W, Celeste, TX 75243, phil@pvgeroge.com.  Phil has to be good with figures, as he has 6 kids!!!   Grin.     Our former CPA was Paul Willingham of Krempien & Willingham.  469.222.3990.  Mr. Willingham was the best CPA we have ever had, but he did not want to fool with the PCAOB requirements and recommend George to us.  We have been blessed by knowing both of these gentlemen.

 

We communicate with our clearing firm, Interactive Brokers mostly via the internet rarely thru 203.618.7791.

They are in Connecticut and I am handled by teams instead of a single person.  You get what you get when the email or phone is answered.

 

Bullish Bob Bagley has the authority to execute and review the BCP as he sees fit.  Our BCP is on our website.  We deal with retail customers and anyone else we can.  Our firm is a correspondent.  We do not maintain customer’s funds or securities.

 

As regards SIPC, we have already suffered through one clearing firm (MJKI) failure.  SIPC just does the best job of anyone on the street for the benefit of the investor.  We have seen the failure of May Financial locally and experienced the failure of MJKI up close and personal.  We have to commend Interactive Brokers, IBKR on the NYSE, on their willingness to listen to correspondent complaints and within reason react positively to some of them.

 

Lastly, we over regulated by FINRA.  There has been a real about face in FINRA over the past 4 years and the guy who headed up the changes is moving on.  We can only pray the new man is up to his standards.  My Firm CRD # is 24761 and my personal CRD # is 10044.  FINRA has striven to be a better regulator for you the public and this website is an example of their endeavors: http://brokercheck.finra.org/.  It is amazing at what is on that website.  Out of the national FINRA, we are in District 6.  My local contact there is Shelly Davis, shelly.davis@finra.org, 972.716.7627.  She is just exceptional and earned my respect and admiration.

 

Our mission critical components are electricity, without which, nothing we have works. Time Warner Cable is 2nd most critical, because our voip phone system,  operates on the internet cable.  Interactive Brokers, our clearing firm, phone-877.422.2757.  I remain your best bet on all contacts.

 

SIPC, http://www.sipc.org/, is the unsung hero of our industry.  I deeply admire them too!

Bullish Org