200 E. Robinson Street, Suite 295 Orlando, FL 32801
200 E. Robinson Street, Suite 295 Orlando, FL 32801
AC Sunshine Securities has developed a Business Continuity Plan to provide procedures for response and recovery in the event of a significant business disruption. The purpose of the Plan is to identify responsible personnel in the event of a disaster; safeguard employees' lives and firm property; evaluate the situation and initiate appropriate action; recover and resume operations to allow continuation of business; provide customers with access to their funds and securities; and protect books and records. The Plan was developed considering the types of business conducted, systems critical to support business, and geographic dispersion of offices and personnel.
The following is a list of those responsible for AC Sunshine Securities' Business Continuity Plan.
| Responsibility | Title or Department |
|---|---|
| Maintain and update Plan | Designated supervisor |
| Approve Plan and Plan revisions; conduct annual review | Firm officer |
| Annual testing of Plan | Designated supervisor |
| Implementation of Plan when a disruption occurs | Emergency Response Team |
| Quarterly review of Emergency Contact Persons and report changes to regulators | Designated supervisor |
| Maintain and distribute Emergency Contact List | Technology staff |
| Maintain and update Books and Records Chart | Technology staff |
| Post Plan disclosure on AC Sunshine Securities’ web site and update, as required | Technology staff |
| Review critical 3rd party assurances or disaster plans or plan summaries: Initial engagement of third party Annually when AC Sunshine Securities’ Plan is reviewed | Technology staff |
| Review critical 3rd party assurances or disaster plans or plan summaries annually when AC Sunshine Securities’ Plan is reviewed | Technology staff |
The Plan has been designed to be implemented in the event of a disaster that results in a significant business disruption. Whether all or only parts of the Plan are implemented depends on the nature of the
disruption. Generally, a significant business disruption would include:
AC Sunshine Securities has designated an Emergency Response Team that is responsible for implementing necessary procedures included in this Plan. The Response Team's action will depend on the nature and scope of the disruption. The "first responder" has the primary responsibility for taking action, and the "secondary responder" acts as a back-up in the event the first responder is unable to act. Where feasible, the two responders are located in different office locations.
AC Sunshine Securities has established an Emergency Contact List that includes the names, phone numbers (cell and land lines), e-mail addresses, and other contact information for individuals critical to AC Sunshine Securities’ business including key employees, key vendors or service providers, regulators, insurance carriers, banks, attorneys, and other key contacts. A copy of the List is provided to each member of the Response Team and other key personnel. This list will be reviewed and updated on at least an annual basis by designated employee involved with day-to-day technical operations.
Alternative Business Locations
In the event employees can no longer conduct business at one of AC Sunshine Securities’ office locations, the following actions may be taken:
1) 200 E. Robinson Street, STE 295, Orlando, FL 32801
Phone contact: 689-689-9686
Contact personnel: Ying Cui
AC Sunshine Securities maintains its books and records in both hard copy or electronic format. The Books and Records indicates whether records are maintained in hard copy or electronic form; location of primary records; and back-up site for records. In the event of an internal or external significant business disruption that causes the loss of AC Sunshine Securities’ records (whether hard copy or electronic records), back-up records will be recovered from the back-up site.
Mission critical systems are systems that are necessary to ensure prompt and accurate processing of securities transactions including order taking, order entry, and make sure connection with clearing firms for order execution, comparison, allocation, clearance and settlement, maintaining customer accounts, and providing access to customer funds and securities.
The Mission Critical Systems identifies systems (or generally describes procedures) that are critical to the operation of AC Sunshine Securities’ business; identifies third parties that provide those systems; and potential alternate procedures or systems for handling these critical functions in the case of a disruption.
Order Management System (OMS): connect to clearing firms through Internet connection. Velox Clearing will provide OMS for all our RRs to place orders for clients. If this OMS is down, we can contact Velox representatives to help to place orders.
Telephone: Internet phone and back up with cell phone
Internet and email server: Robohigh, Inc.
Contact: David Ada-Winter, IT consultant at Robohigh, email: david@ada-winter.com
Phone #: 201-927-3079
address: 8761 The Esplanade, STE 30, Orlando, FL 32836
Email back up: Intradyn and Robohigh Intradyn mainly to retention and archive our emails for regulatory purpose. Robohigh maintains our email server and create and maintain email users, and provide support for email users.
Velox online trading platform for clients. Velox will provide white label Internet website trading system for our clients to place orders on Internet by themselves. If clients cannot access their internet trading website, they can call our RRs or Velox representatives to help to place orders.
The following describes procedures for assessing changes in operational, financial, and credit risk exposures in the event of a significant business disruption.
In the event of a significant business disruption, alternative systems will be implemented to communicate with customers, employees, critical business constituents (banks, counter-parties, etc.), regulators, and other key parties depending on the nature and impact of the disruption. Communication systems are described in the section "Alternative Communications.
In the event of a significant business disruption, AC Sunshine Securities’ financial status will be evaluated to determine the need for additional financing or identify capital deficiencies including the following:
AC Sunshine Securities may use a wide range of communication systems to communicate with its customers, employees, counter-parties, and regulators including telephone; mail; fax; e-mail; and personal meetings. Procedures for instituting alternative communications in the event of a significant business disruption include the following, depending on the nature of the disruption:
In the event of a significant business disruption that disables communications systems, alternative system procedures will be implemented, including the following:
In addition to the above, AC Sunshine Securities has developed a system to enable senior management to contact employees in the event of an emergency. The system is proprietary and confidential
Communications with regulators will be conducted using the most expedient available communication system. The designated Response Team person will contact regulators regarding any major business disruption and plans for continuing business.
New York regional contact:
To be assigned
Regulatory Coordinator
FINRA | New York District Office
One World Financial Center
200 Liberty Street, 9th Fl | New York, NY 10281
Tel: 212.858.4197 | Fax: 212.858.5122
Andrew M. Calamari, Regional Director
200 Vesey Street, Suite 400
New York, NY 10281
Phone: 212-336-1100
E-mail: newyork@sec.gov
This section describes business Continuity procedures regarding third parties that are critical to the conduct of AC Sunshine Securities’ business. In most instances, contracts with critical third parties will include assurances regarding the third party's disaster recovery plans. A disruption impacting AC Sunshine Securities’ ability to conduct business may occur either at AC Sunshine Securities itself or at the third party. The Business Constituent, Bank (Appendix C to the Plan) identifies key parties and potential alternatives in the event of a disruption.
Velox Clearing, 2400 East Katella Ave, Suite 725, Anaheim CA, 92806
Duke Du email: ddu@velox-global.com, phone: 949-352-4706
Determine whether the third party is able to continue providing critical services.If not, identify and contact an alternate third party to provide services.
Determine whether the bank/financial institution is able to continue providing financing.If not, identify and secure alternative financing.
In the event AC Sunshine Securities’ systems for accepting customer orders are disrupted, alternative systems will be communicated to customers and to employees including, where appropriate:
When customer access to funds and securities is impacted by a significant business disruption, customers will be notified by whatever expedient means is available (telephone, e-mail, etc.) regarding who may be contacted to request funds or securities. If AC Sunshine Securities is unable to continue business operations, customers will be notified of an alternative financial institution where they may conduct business and access their funds and securities.
In the event SIPC liquidation of AC Sunshine Securities’ business is required, designated personnel will work with the SIPC-appointed trustee to wind down AC Sunshine Securities’ operations and transfer customer funds and securities.
1667 K St. N.W., Suite 1000
Washington, D.C. 20006-1620
Telephone: (202) 371-8300
Fax: (202) 223-1679
Email: asksipc@sipc.org
The Business Continuity Plan is communicated to employees as follows:
There are all employees meeting to discuss AC Sunshine continuity plan. They will have copy of the major part of our continuity plan related to each employee, including Emergency Response Team and their contact information. The most recent Emergency Contact List is provided to key employees.
A current copy of the Plan is provided to the Emergency Response Team and key employees with responsibilities for aspects of the Plan.
The Plan will be reviewed on at least an annual basis and revised as needed. Each revision will be approved by the designated senior manager and copies of the revised Plan distributed to the Emergency Response Team and key employees. Some material events require updating the Plan when they occur, including:
When the Plan is reviewed, the procedures and accompanying lists and charts will be reviewed and updated as needed including the:
| Ying Cui | 689-689-9686, ycui@ACSunshine.us |
A written record of the annual review including the date reviewed and name and signature of the reviewer will be retained by Compliance.
If you have questions about our business continuity planning, please contact your AC Sunshine Securities’ Representatives. You may also contact the AC Sunshine Securities home office by visiting the Customer section of our website at http://www.acsunshine.com or send us email to info@acsunshine.com.
