Business Continuity Policy

Lightspeed Financial Services Group LLC (“Lightspeed”) has developed a Disaster Recovery and Business Continuity Plan (“Plan”) in the event that a function deemed critical to Lightspeed’s ongoing business operations fails. The plan will assist Lightspeed in minimizing any business operational issues that result from an unexpected event or disaster.

Lightspeed’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and Company property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing customers to transact business. In the event that the Company determines that it is unable to continue business, Lightspeed will assure customers prompt access to their funds and securities.

Lightspeed’s plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only Lightspeed’s ability to communicate and do business, such as a failure of a critical system, or a fire in the Lightspeed offices. 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.

In the event of an SBD, Lightspeed intends to continue its operations to the extent reasonable and practical under the circumstances and will place utmost priority in re-establishing the data and operational systems necessary to provide our customers with prompt access to their funds and securities, and with the ability to close out open positions. 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 what alternatives they have to send their orders to us.

Lightspeed 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 firms. Customers who are not introduced by Lightspeed to their clearing firm are advised to contact that firm for information about business continuity plans and contingencies in the event of a business disruption to their trading.

Lightspeed backs up its records on a periodic basis, keeping copies of essential databases, software programs, and other records offsite. Additionally, our clearing brokers have records of all customer activity that has been submitted to them. Overviews of the Plans of our clearing brokers can be found online at the following web sites:

Wedbush Securities Inc.

Interactive Brokers

TYPES OF DISRUPTIONS

Lightspeed’s Plan foresees three general classes of business disruptions:

  1. Significant but not catastrophic disruption at Lightspeed’s main office
  2. Catastrophic disruption at Lightspeed ’s main office
  3. City-wide, regional or other disruption that temporarily limits access to and/or the functioning of the Lightspeed main office or data center (“Office”).

Significant but not Catastrophic Disruption at Lightspeed’s Office Limited disruptions affecting communications lines, computer hardware, or other related systems typically can be addressed through the use of certain redundant systems used by staff in various office locations.

Catastrophic Disruption at Lightspeed’s Office The Company’s response to a catastrophic disruption at our Office will depend on the extent of the damage. In the event of a total loss of Lightspeed’s Office, the Firm is able to shift various data processing and service duties to alternative offices of Lightspeed. We also will coordinate with our clearing firms to permit customers to close out open positions. In addition, as communications permit, we will inform our customers what alternatives they have to send their orders to us.

Beyond the initial aftermath of the total loss of Lightspeed’s Office, the Company would evaluate the nature of the disruption, the availability of our systems and personnel, our financial condition, the condition of the national and global financial markets, and other factors, as appropriate, to determine whether to restore full brokerage operations or to discontinue brokerage operations and assist customers in transferring their accounts elsewhere.

City-Wide, Regional or Other Disruption that Temporarily Limits Access and/or the Functioning of the Lightspeed Office For a city-wide, regional or other disruption that temporarily limits access to and/or the functioning of the Lightspeed Office, the Company’s response would vary dependent upon the exact nature of the disruption and its impact on the financial markets and our Waltham office. These types of disruptions include the Company having to evacuate the Office temporarily due to a bomb threat or smoke damage on another floor. Lightspeed’s response would be similar to a catastrophic disruption to the Lightspeed offices; however, restoration of full services would be quicker, but resumption time is dependent upon the exact nature of the disruption.

ONGOING ENHANCEMENTS
The Waltham office is in a geographically separate region and is intended to be able to assume most functions of our other locations when dealing with the Lightspeed trading system and related activities in the event of a disruption in the Main or other offices. Please contact Lightspeed at (888) 577-3123 for further details about these capabilities. Lightspeed’s Business Continuity Plan, including this disclosure, will be amended to reflect new capabilities and enhancements.

DISCLAIMERS
There are innumerable potential causes of a business disruption, and the events that cause them may vary significantly in nature, size, scope, severity, duration and geographic location, and will result in distinct degrees of harm to human life; firm assets; the banks, exchanges, securities firms and ECNs with which the firm conducts business; and local, regional and national systems infrastructure (e.g., telecommunications, Internet connectivity, power generation and transportation) that could affect Lightspeed’s recovery in a variety of ways. Lightspeed reserves the right to flexibly respond to business disruptions in a situation-specific manner which the Company deems appropriate.

Nothing in this document is intended to provide a guarantee or warranty regarding the actions or performance of Lightspeed Financial Services Group LLC, its computer systems, or its personnel in the event of a significant business disruption. Lightspeed may modify its Disaster Recovery and Business Continuity Plan and this disclosure at any time. The Company will post updates to this disclosure on our website.

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