DESCRIPTION OF OUR BUSINESS CONTINUITY PLAN
To Our Valued Clients: As you may be aware, at the time of the tragic events of Sept. 11, 2001, many of the country’s financial services firms had offices in the World Trade Center or surrounding buildings. Immediately after the tragedy, many investors experienced difficulties in accessing their accounts and their assets. An investigation by government regulators revealed that these difficulties arose from the fact that many firms were not prepared to deal with a sudden disruption of their businesses, whether by natural disasters, acts of terrorism, or other emergencies.
To address these issues, government regulations now require financial services firm to develop a Business Continuity Plan to meet the challenges which might arise in the event of an emergency. Below, we have summarized important information which you should know about our Plan. Of course, the timing and impact of natural disasters and other emergencies are unpredictable. Consequently, our response to specific events must remain be flexible and may require sudden and unexpected changes in our Plan.
Contacting Us After a significant business disruption, you should first try to reach your VSR Representative at his or her local office. If you cannot reach your Representative, you should try to reach the VSR Home Office at 913-498-2900. Alternatively, you may go to our website, www.vsrfinancial.com, where we will post emergency contact information. If you have an account with our clearing firm, First Clearing LLC, you may contact First Clearing’s Customer Service Department at 877-549-1390 for access to or information about your funds or securities, or to process orders for your account. If you have an account with a mutual fund company or an insurance company, you should contact that company directly at the telephone number or website shown on statements they send you.
Varying Disruptions Significant business disruptions can vary in their scope, and may affect only our firm or our building, or they may affect the business district, city, or region where our headquarters is located. Within each of these areas, the severity of the disruption can also vary from minimal to severe. If a disruption affects only our firm or building, we will, if appropriate, transfer our operations to another local site, to the extent reasonably possible, and use reasonable efforts to resume business in a timely fashion. If a disruption affects our business district, city, or region, we will attempt to transfer our operations to a site outside of the affected area, and resume time sensitive functions as soon as key personnel and operations can reasonably be relocated. In either situation, we will attempt to notify you through our website www.vsrfinancial.com with respect to our plans and our progress. If the business disruption is so severe that it prevents us from remaining in business, our clearing firm, or the mutual fund companies or insurance companies which hold your accounts will be responsible for providing prompt access to your funds or securities. It is possible that your orders and requests for access to your funds or securities could be delayed during this period.
Our Business Continuity Plan In the event of a significant business disruption, our Business Continuity Plan provides that we will protect our employees, property, books and records, and make a financial and operational assessment of our business, with the goal of allowing us to resume business as soon as reasonably practical, given the scope and severity of the disruption. In addition, our Plan addresses: data back up and recovery; mission critical systems; alternative communications with customers, employees, and regulators; alternate physical locations for our employees; impact on critical suppliers, contractors, and bank relations; regulatory reporting; and steps we will take to help our customers obtain prompt access to their funds and securities.
According to First Clearing’s current business continuity plan, we understand that in the event of a significant business disruption, it will endeavor to continue to provide essential services to VSR and its clients. First Clearing has divided its corporate offices in Richmond, Virginia, between two primary locations which are located approximately 20 miles apart. Should one of the primary buildings be affected by a disruption, the other building can be used to help restore operations. First Clearing maintains the critical records regarding the customer accounts they hold. According to their plan, those records are backed-up and maintained in geographically separate areas.
In the unlikely event of a citywide or regional disruption, First Clearing has established a recovery site approximately 150 miles from its headquarters that can be used to restore time sensitive functions as soon as key employees are relocated to the facility. Additionally, as an affiliate of Wachovia Corporation (the fourth largest bank holding company in the United States), First Clearing believes it will be able to take advantage of available facilities of other Wachovia affiliates that may be located in other geographic regions. In the event of a significant disruption, First Clearing has developed alternative service arrangements, systems, locations and contingency plans to ensure that essential services are restored as soon as reasonably practical. However, your orders and requests for funds and securities could be delayed during this period.
For more information If you have questions about our business continuity planning, you can contact us at 913-498-2900 or go to our website at www.vsrfinancial.com. Because business continuity plans are subject to modification, we will post to our website significant changes to our plan. Alternatively, we will provide you upon written request with a copy of this notice.
