BCP Client Disclosure and Acknowledgement
Date: 12/18/2014
Subject: Business Continuity Plans FINRA Rule 4370
Effective Date: 08/01/2008
Purpose of this disclosure
FINRA Rule 4370 requires member firms to create and maintain a written business continuity and contingency plan and procedures relating to an emergency or significant business disruption (“SBD”)
Firm Policy
In the event of a SBD it is the policy of Bullish Bob Bagley Securities, Inc. to react quickly and efficiently and according to pre- tested and pre-planned procedures to ensure the safety of our employees, associates, customers, as well as critical operational and account data. We will provide information to employees, associates and clients both pre and post SBD to ensure operations are run as smooth as possible during this critical time.
Significant Business Disruption (SBD)
Definitions:
Our firm’s business continuity plan covers three types of disruptions:
• Firm Disruptions (FD) – Includes but are not limited to firm disruptions such as a building fire, a building power outage, computer or network malfunction or virus infection disruption or disconnection of telephone services.
• Local Disruptions (LD) – Includes but not limited to local disruptions such as regional floods, fire, terrorist attack, earthquake, tornado, hurricane, chemical spill or regional power, telephone or internet outages.
• Regional Disruptions (RD) – Includes but not limited to regional disruptions such as power grid failure or regionally affected natural disaster or terrorist attack.
FD
In the event of a FD, clients can call our alternative location at 214.404.6204
for information and instructions. Under this scenario, Bullish Bob Bagley Securities, Inc. will plan to continue doing business under
this scenario with a period of two hours of the FD.
LD
In the event of a LD, clients can call our alternative location at 214.404.6204 or if the secondary location is effected by the LD, clients can call the ClearingFirm-InteractiveBrokers at 312.542.6846 for information and instructions. Under this scenario, Bullish Bob Bagley Securities, Inc. will close operations and inform our clients via phone, e-mail or website our recovery time.
RD
In the event of a RD, clients can call our alternative location at 214.404.6204 or if the secondary location is effected by the RD, clients can call our Clearing Firm, Interactive Brokers at 312.542.6846 for information and instructions.
Data Back-up
Bullish Bob Bagley Securities, Inc. backs up its critical information and stores this information a a designated off-site location
in the event of a destruction of critical documents caused during a SBD.
Plan review and updates
This Business Continuity Plan is subject to change and is modified and tested at least annually for updates and revisions. An updated and current copy of this summary is posted and can be viewed at http://www.bullish.org, Clients can also request this document by calling the firm and a copy will be mailed via U.S mail to the client.
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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 one 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 72 and on Medicare. That does not mean I am going to retire or am even thinking about it.
In our office, 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 Spectrum. We are serviced electrically by the city owned, Garland Power & Light.
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. We have gone for international backup on our secondary phone system, or our cell phone, 214.404.6204. It is serviced by www.lycamobile.us. This is a Polish based phone company. Lyca is wolf in Polish. I guess this is attributable to my eating too many Kolaches in West, TX. Lycamobile piggybacks T-Mobile, but check out the website for the affordable plans.
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 Kwikset 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 9 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 and 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 are regulated by FINRA. There has been a real about face in FINRA over the past year and the guy who headed up the changes is still working and seems to be a breathe of fresh air in FINRA. 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 has earned my respect and admiration.
Our mission critical components are electricity, without which, nothing we have works. Spectrum Cable is the 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!