Bridge Alternative Investments Inc. and Bridge Alternatives Securities, LLC. ("Bridge") have developed the following business continuity/disaster recovery plan. It is intended to provide business continuation in the event of a natural disaster such as hurricanes, earthquakes, power outages, and floods, as well as disasters that may be caused by terrorist acts. The plan provides for backup of critical information, relocation to alternative work sites, and alternative contact means for appropriate personnel.
Bridge believes that disaster recovery and business continuity issues are of utmost importance and has taken a proactive approach to ensure that it has an adequate plan in place. The need for Bridge to provide services to our customers in the event of a business disruption is vital, as is the importance that third-parties can contact Bridge personnel in the event of an emergency.
Accordingly, Bridge has implemented the following plan, as required by NFA Compliance Rule 2-38 and NFA Interpretive Notice 9052, to ensure business continuity in the event of a disaster or business interruption.
- In the event Bridge’s main office, 207 E. Westminster Ave. Suite 210 Lake Forest, IL 60045 becomes unavailable to conduct operations, Bridge has designated the following backup facility, located in a separate geographical location and on a different power grid, which is readily accessible to firm personnel, where firm personnel can resume business activities:
2806 Knollwood Ln
Glenview, IL 60025
This location has an ample supply of computers. This location utilizes a different telecommunication vendor than the main office. Furthermore, this location has high speed internet access and phone service.
- Laptops are regularly used and therefore, employees can also work from their homes, along with their cell phones.
- Bridge backs up pertinent computer files and essential documents (e.g. customer files, accounting records, legal records, compliance information, etc.) using cloud technology. Such information can be accessed from any location that has internet access.
- Copies of vital paper documents are scanned and backed up.
- A listing of customer contact information, including names, phone numbers, and electronic mail addresses are maintained in a database that is available on an app.
- This plan is provided to all key employees of Bridge and copies of the plan have been made and given to employees. Additionally, a copy of the plan is maintained on file at the backup facility identified above.
In the event the plan is updated or modified, Bridge will ensure that the edited plan is distributed to key employees and that all other employees are notified of changes to the plan.
Implementation of Disaster Recovery/Business Continuity Plan
- In the event of a business disruption, Bridge shall notify all of its customers of the disruption to the company’s operations as soon as practically possible.
- Bridge shall notify essential vendors of the disruption to the company’s operations as soon as practically possible.
- Bridge shall notify the carrying brokers (FCMs) of the disruption to the company’s operations as soon as practically possible.
- Notification shall be made through whatever means are most appropriate at the time, for example, through email, posting on its website, telephone, etc.
- Ryan Duncan would contact each employee in the event of a disaster. In the event of a short term absence from the main office, employees would most likely conduct business operations from their residence; However, in the event of a longer term absence, Bridge’s employees would meet at the alternate work location as soon as practical.
- Customers are provided with contact numbers at the FCM carrying their account in the event Bridge personnel cannot be reached. Numbers provided include order departments and client services. Bridge would also provide instructions on its website for contacting the FCMs.
Disruptions of Third-Parties
Bridge has considered the impact of possible disruptions on behalf of third parties such as the FCMs, CTAs, third party account controllers, compliance/accounting companies, and other financial institutions that support Bridge’s business and operations. Bridge obtains reasonable assurance that the third parties have a disaster recovery/business continuity plan in place. In the event Bridge becomes notified that a disaster has affected a third party that conducts business with Bridge, the following course of actions will take place:
- Ryan Duncan will assess the impact on the Company by contacting the applicable third party. This contact will generally be via e-mail or telephone depending on the type of impact. Bridge has cell phone information for its key contacts at the FCMs and its key vendors and therefore, Bridge will implement every reasonable and available method to contact FCMs and key vendors. In this contact, Bridge will determine if the impact will directly affect Bridge’s customers or its compliance with the rules and regulations governing its operations;
- After determining the severity of the impact on the third party’s business operations, Ryan Duncan will determine the proper course of action and whether or not to put Bridge’s own disaster recovery plan into place;
- In the event an FCM is impacted by a disaster, Bridge has the ability to establish several relationships with other FCMs in its capacity as an independent introducing broker whereby Bridge can enter into a new agreement within 24 hours and move the customer’s liquid assets and positions to a new FCM in the same time frame (assuming customer funds are not at risk or frozen due to regulatory measures).
- In the event a financial institution (e.g. a bank) doing business with Bridge is impacted by a disaster, Bridge will immediately open a new account and will fund the account to ensure the Company has sufficient capital to meet the regulatory capital requirements.
- In the event Bridge’s third-party accountants/consultants are impacted by a disaster, Bridge will either compile its own financial statements or hire another third-party accountant to compile the monthly financial statements. Each month Bridge obtains and maintains copies of the prior month’s financial statements from its current accountant. This would allow for a smooth transition by the successor accountant.
- Bridge can communicate with customers via telephone, instant messaging, or email. In the event the telephone company experiences a disruption in service, Bridge will contact customers via email. In the event the internet company experiences a disruption in service, Bridge will contact customers via telephone.
- If customer accounts are impacted by a third party’s disaster, Bridge will monitor the progress of the third party’s implementation of their disaster recovery plan and will notify all investors either by phone, e-mail, mail, or fax regarding the impact on its business.
Infectious Diseases and Pandemics
Infectious diseases are caused by pathogenic microorganisms, such as bacteria, viruses, parasites or fungi; the diseases can be spread, directly or indirectly, from one person to another.
An epidemic is a widespread occurrence of an infectious disease in a community at a particular time.
A pandemic is a disease outbreak occurring over a wide geographic area and affecting an exceptionally high proportion of the population such as the country or the entire world.
Throughout history the United States has had major outbreaks of illnesses in communities, states and the country. In the event of an epidemic or pandemic our company personnel may be unable to commute to the regular and customary business office, whether being a main or branch office.
Such inability for an employee or Associated Person (“AP”) to commute to the main or branch office may be a result of any of the following:
- Schools or day-care centers are closed, and a child would need to be cared for;
- There is a need to care for elderly parents or grandparents;
- Public transportation was halted; or,
- A partial or total shut-down was directed by local or federal government.
The Company’s key relationships are outlined in its business continuity and disaster recovery plan. The Company will re-assess the potential risks a pandemic pose to these relationships and how a pandemic may materially impact the business. The Company will take every measure to mitigate any potential risks.
The Company shall provide the proper tools that can be used at home for an AP to carry out his/her responsibilities. Such tools would include, for example: a computer or laptop with the same software that runs at the main office which includes virus protection; a printer; time stamp machine; telephone; and if necessary, a webcam so meetings can be held face to face over common software such as Microsoft Teams, Skype, or Zoom.
The Company will notify its customers, counterparties, and vendors that it is enforcing its business continuity plan and personnel will be operating from their residences.
Personnel should ensure all critical files and documents are either physically with them or accessible via the Company’s network or cloud service while operating from their residences.
NFA Registration Rules require a Member firm to list as a branch office any location other than the main office from which APs are engaged in activities requiring registration. Furthermore, each branch office is required to appoint a branch office manager who successfully completed the Series 30 Branch Manager Examination. Generally, NFA and the CFTC would not pursue disciplinary action against a Member firm that permits APs to temporarily work from locations not listed as a branch office and without a designated branch office manager during an epidemic or pandemic.
The Company would allow its APs to work from home temporarily during an epidemic or pandemic. Office days and hours will remain the same as if employees or APs are working at the main office or a registered branch office based on futures market exchange hours. Employees and APs’ duties, obligations, and responsibilities will remain unchanged. Employees and APs would be required to return to the main office or registered branch office once deemed safe by local, state, or federal officials.
The Company’s compliance officer or his or her designee will be responsible for enhanced supervision of employees working remotely, particularly those employees that are registered associated persons. The Compliance Officer may invoke the following procedures:
- Increase the level of review over email communications;
- Increase the level of review over APs trading their own personal futures accounts;
- Contact the employees throughout the day, on a scope basis, especially registered APs;
- Contact customers from time to time to determine how their experience was during the time the Company was operating pursuant to its business continuity plan.
If Company personnel are required to tape record all solicitations and discussions with prospective customers pursuant to NFA’s enhanced supervisory procedures, then solicitations of prospective customers shall NOT be permitted until APs return to the office
Bridge will test its disaster recovery/business continuity plan on an annual basis. Bridge will maintain written evidence that the plan was tested along with the results of the test.
Communication with the National Futures Association
Bridge provides National Futures Association with emergency contact information for individuals who are authorized to communicate with the National Futures Association in the event of an emergency (Note: This information can be updated via the NFA annual questionnaire accessible on the National Futures Association web-site: https://www.nfa.futures.org).