BUSINESS CONTINUITY PLAN
Our firm’s policy is to
respond to a Significant Business Disruption (SBD) by safeguarding our
employees lives and the firm’s property, making assessments of the financial and
operational abilities of the firm, quickly setting recovery and resuming
operations, protecting the firm’s books and records and allowing clients to
continue to transact business. We will also assure customer prompt access to
their funds in WRP Investments is unable to continue conducting business.
Please be advised that WRP Investments does not hold any client funds.
Brokerage accounts are cleared through National Financial Services, LLC (a copy
of NFS’s Business Continuity Plan is attached) Mutual
fund and variable product sales are direct with the mutual fund and insurance
companies. Clients will continue to have
access to their funds and accounts regardless of what happens to WRP
Investments, Inc.
We plan for the following 2
types of SBDs, internal, such as a fire or power
loss, and external, such as a terrorist attack or widespread power failure.
Internal SBDs have been anticipated as shown in the
attached procedures. See attachments. In
the event of internal SBDs, clients will continue to
be able to contact their representative and transact business through either
the representative or the fund or insurance company.
External SBDs will require WRP Investments to rely heavily on other
organizations and systems, especially on the capabilities of our clearing firm
and the mutual fund and insurance companies that we do business with.
WRP Investments conducts
business, primarily in the packaged product line, i.e. mutual funds variable
annuities and variable life. We also conduct business in equity and fixed
income investments through our clearing firm National Financial Services, LLC.
Our firm is considered an introducing firm, therefore we do not hold customer
funds or securities, nor do we disburse customer funds or securities. All
transactions are sent either to our clearing firm, or to the mutual fund or
insurance company. These outside firms execute, compare, allocate, clear and
settle the customer trades. These outside vendors also maintain our customer’s
accounts and will grant the customer access to their accounts. They will also deliver funds, cash, or
securities to the clients on demand. WRP Investments services only retail
clients and we do not engage in any private placements.
Our main office is at
CUSTOMER ACCESS TO FUNDS AND SECURITIES
WRP Investments, Inc does
not hold customer funds or securities. If case of a SBD, clients can contact
the entity holding their investments, either our clearing firm or the mutual
fund or annuity company that holds the client’s assets. If phone service is still working, we can
take customer orders and forward these orders to our clearing firm. The mutual fund companies and annuity
companies have listed their phone numbers and web site addresses on customer
statements. Clients can contact either their registered representatives, who
are off site from the home office for help, or contact the investment companies
direct for support.
We will notify our clients,
through their representatives that we have experienced a SBD and to contact
wither their representative for assistance to go directly to the fund or
annuity company. Clearing issues can be
resolved in the same manner.
In the event of a SBD that
causes the loss of our papers records, we can physically recover them from our
back-up site. If activity from our primary site is not possible, we will
continue operations from one of our back-up sites. For loss of electronic
records, we will physically recover the information from our back-up site and
if the primary site is inoperable, work from one of our back-up sites
FINANCIAL AND OPERATIONAL ASSESSMENTS
In the event of an SBD, we
will immediately identify what means will permit us to communicate with our
clients. Since the majority of our clients work with representatives outside
the main office, we will communicate through the registered representatives;
either via cell phones, regular telephone service, e-mails, or the
internet. We will also communicate with
our vendors, regulators, and critical business contacts, such as banks and
investment contacts.
MISSION CRITICAL SYSTEMS
WRP Investments “mission
critical systems” are those that ensure prompt and accurate processing of
client’s securities transactions, including order taking, entry, execution, and
allocation of accounts. They also allow access to client accounts. WRP has no propriety software, and all of our
client account access is web-based.
Therefore, client information can be accessed from the internet wherever
WRP Investments may have to set up. Client files are held at the various fund
and annuity companies and also at our clearing firm.
While we have the primary responsibility
for establishing and maintaining our business relationships with our customers,
the fund, annuity, and clearing firms have the responsibility to allow us to
contact them via phone, letter, e-mail, or through their web-sites in order to
purchase, allocate, or service our client accounts.
Our contracts with these companies require that they also
have in place a business continuity plan. They have represented that they will
advise us of material changes in their plan(s)