Notice of Tribal Capital Markets, LLC Business Continuity Plan
Emergency Contact Persons: Our firm’s emergency contacts are as follows:
Fixed Income: Alan Mele at amele@tribalcap.com, 212-606-0226 or 908-421-0390 or John Barry at jbarry@tribalcap.com, 212-606-0226 or 561-445-2600.
Equities/Compliance: Glenn Chaleff at gchaleff@tribalcap.com, 212-850-2291 or 201-232-0737
These names will be updated in the event of a material change and our Executive Representative, John Barry will review them as necessary.
Firm Policy: In the event of a Significant Business Disruption (“SBD”), the firm will act to assist the safety of its employees and then to resume operations of business as quickly as possible in order to allow customers to conduct transactions and access their funds.
Our plan anticipates both internal and external SBD’s. In the event of an occurrence such as a terrorist attack or regional blackout, we are prepared to route trades through RBC Correspondent Services, a division of RBC Capital Markets, LLC. (“RBC”) order management system platform as long as the exchanges are open. Glenn Chaleff, Chief Compliance Officer, is responsible for approving the plan and for conducting the annual review. Managing Partners, John Barry and Alan Mele have the authority to execute this Business Continuity Plan (“BCP”).
Business Disruption: Tribal Capital Markets, LLC (“TCM”) conducts business in equities, bonds, mutual funds and options with both Retail and Institutional clients. TCM is an introducing firm, clearing through RBC Correspondent Services, a division of RBC Capital Markets, LLC. During a significant business disruption, if our clients are unable to reach us either by telephone or internet and require access to their accounts, they are advised to contact our clearing firm, RBC Correspondent Services a division of RBC Capital Markets, LLC, for access to their funds and securities. Clients are advised to refer to their Account Statements for contact information.
Office Location: The main office of TCM is 42 Broadway, 3rd Floor, New York, N.Y. 10004. The main telephone number is 212-606-0226. This is one of the two OSJ offices of TCM and order receipt and entry is effected from this office.
Alternative Physical Locations of Employees:
In the event of a temporary SBD, our staff will work from the Firm’s second OSJ, located at 324 Dover Court, Morganville N.J. 07751. Persons responsible for order entry will have access to RBC systems, trade entry and execution systems, and Bloomberg terminals at this location in order to comply with FINRA requirements. In the event of a catastrophic event or terrorist attack that results in a permanent loss of structure, those members of the firm who are able, will regroup temporarily at the 324 Dover Court location in Morganville, until new permanent quarters can be located.
Custody: Our firm does not maintain custody of customer’s funds or securities. The aforementioned are maintained by our clearing firm, RBC Correspondent Services, a division of RBC Capital Markets, LLC. located at 60 South Sixth Street Minneapolis, MN 55402.
Data Backup and Recovery: The primary books and records of the firm are held at our main address at 42 Broadway, N.Y., N.Y. 10004. Chad Kirschenblatt is the firm’s Financial Operations Principal and is responsible for the maintenance of these books and records. Customer documents are transmitted to our clearing firm and may be accessed by them in the event of an emergency. Secondary copies of our legal documentation at the office of our attorney, Herrick Feinstein, LLP, 2 Park Ave. N.Y., N.Y. 10016, 212-5921400. Secondary copies of our financial records are maintained at the office of our CPA, Sanville and Co., 1514 Old York Rd., Abington, PA. All of the above are readily accessible as necessary.
Mission Critical Systems: TCM receives orders from clients verbally, via telephone or in person in our offices. In the event of an SBD, either internal or external, our registered personnel will take customer instructions via office or cellular telephone. Our firm relies by contract on our clearing firm to provide order comparison, maintenance of customer accounts, delivery of funds and securities and access to customer accounts. If telephone service to TCM is disrupted, our clients may place liquidating orders directly with RBC phone number of trading desk.
Alternative Communications between the Firm and Regulator: In the event of an SBD, we would communicate with our regulators using the telephone, fax, email or U.S. Mail, as necessary.
Alternative Communication between Employees of the Firm: Each member of the firm has a list of other member’s current contact information. We will communicate by any available method during a disruption of services.
Disclosure of Business Continuity Plan: We will make a copy of our SBD policy available to new clients at the opening of an account. We will also make the plan available upon client request and once yearly through special notice.