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Our Firm’s three emergency contact persons are: 

Rohit Manocha, (212) 610-1505   rmanocha@tri-artisan.com

Gerald H. Cromack, (212) 610-1510   gcromack@tri-artisan.com 

Julie Adams, (212) 610-1524   jadams@tri-artisan.com

 

Our Firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations and protecting all of the firm’s books and records.  

 

Our plan anticipates two kinds of SBDs, internal and external.  Internal SBDs affect only our Firm’s ability to communicate and do business, such as a fire in our building.  External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption.  Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

 

Rohit Manocha, Managing Director, a registered principal, is responsible for approving the plan and for conducting the required annual review.  Rohit Manocha has the authority to execute this BCP.

 

Our Firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection.  We have given Fulvio & Associates, L.L.P. a copy of our plan.  An electronic copy of our plan is located on SERVER1 on the P drive in the Compliance folder.

 

Tri-Artisan Partners provides financial advisory services to public and private companies including advice on mergers and acquisitions, divestitures, joint venture arrangements, corporate sales spin-offs, restructurings and sale of securities in public and private markets. 

 

Our clearing firm is Southwest Securities, Inc., 1201 Elm Street, Suite 3500, Dallas, TX 75270.  Our contact person at that clearing firm is William Felder, (214) 859-9128.  Our clearing firm has also given us the following alternative contact in the event it cannot be reached:

 

Sean Malloy

Southwest Securities, Inc.

17 Washington, 4th Floor

Norwalk, CT 06854

(203) 852-8082

 

 

110 East 59th Street, 37th Floor

New York, NY 10022

(212) 610-1500

 

Employees may travel to the office by means of foot, car, subway, train, bus, boat or plane.  All of Tri-Artisan Partners business activities take place at this location.

 

Fulvio & Associates, L.L.P.
5 West 37th Street, 4th Floor
New York, NY 10018

 

 

 

Rules:  FINRA Rule 3510(a); Securities Exchange Act Rule 15c3-1; 15 U.S.C. 78eee (2003).

 

The Firm maintains its primary hard copy financial books and records at 110 East 59^th Street, 37^th Floor, New York, NY 10022. 

Back-up hard copy financial books and records are maintained at Fulvio & Associates L.L.P., 5 West 37th Street, 4th Floor New York, NY  10018, (212) 490-3113.  Electronic back-up of these back-up hard copy financial books and records is performed weekly by Fulvio & Associates L.L.P.  

The Firm maintains its physical and electronic records at 110 East 59^th Street, 37^th Floor, New York, NY 10022. 

Backupnation.com backs up the Firm’s electronic records daily, 7 days a week by automated computer process – gathering, encrypting, compressing and transporting to and storing in encrypted and compressed form, in backupnation.com data centers located at certain off-site facilities.

In the event of an internal or external SBD that causes any loss of records, the Firm will recover them from the backupnation.com off-site facilities or from Fulvio & Associates L.L.P.

Rohit Manocha, (212) 610-1505 is responsible for the Firm’s physical and electronic records.

In the event of an SBD, we will immediately identify what means will permit us to communicate with our employees, critical business constituents, critical banks, critical counter-parties, and regulators.  Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include telephone voice mail and secure e-mail.  In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).

 

 

In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance.  We will contact our clearing firm, critical banks, and investors to apprise them of our financial status.  If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will file appropriate notices with our regulators and immediately take appropriate steps to attempt to procure additional financing.

 

1.      Order Taking

2.     Order Entry

3.     Order Execution

4.     Other Services Currently Provided to Customers

 

 

 

A.         Customers

 

We now communicate with our customers using the telephone, e-mail, fax, U.S. mail, overnight mail and in person.  In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.  For example, if we have communicated with a party by e-mail but the Internet is unavailable, we can call them on the telephone and follow up where a record is needed with a paper copy in the U.S. mail.

 Alternatively, in the event of an SBD which displaces the Firm from its offices, our customers can attempt to contact the Firm at its back-up office location at c/o Fulvio & Associates L.L.P., 5 West 37th Street, New York, NY 10018 Tel: (212) 490-3113.

 

 

B.         Employees

 

We now communicate with our employees using the telephone, e-mail, and in person.  In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party, namely cell phones and e-mail. We will also employ a call tree so that senior management can reach all employees quickly during an SBD.  The call tree includes all staff home and office phone numbers. 

 

C.         Regulators

 

We are currently members of the FINRA and are registered with the SEC.  

 

Our Core Examiner at the FINRA is: 

 

Karen Davis

Investigator Specialist

FINRA District No. 10

One Liberty Plaza

New York, New York 10006

(212) 858-3913

 

The SEC’s Northeast Regional Office which covers our Firm can be contacted at:

 

SEC – Northeast Regional Office

233 Broadway

New York, New York 10279

Mark Schonfeld, Regional Director

(646) 428-1500

 

We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person.  In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with either party. 

 

In the event of an SBD, the Firm’s FINRA core examiner should be contacted at:

 

Karen Davis

Investigator Specialist

FINRA

District No. 10

One Liberty Plaza

New York, NY 10006

Tel: (212) 858-3913

 

In the event of an SBD, the Firm’s SEC regional office should be contacted at:

 

SEC – Northeast Regional Office

233 Broadway

New York, New York 10279

Mark Schonfeld, Regional Director

(646) 428-1500

 

In the event of an SDB which disrupts the Internet or other electronic system used for the filing of the Firm’s FOCUS Reports, a “hard copy” of the FOCUS Report should be delivered by the fastest alternate means then available (i.e. by hand, overnight delivery or U.S. mail) to: 

 

Karen Davis

Investigator Specialist

FINRA

District No. 10

One Liberty Plaza

New York, New York 10006

 

with a copy to:

 

FINRA

P.O. Box 9401

Gaithersberg, Maryland  20898

 

 

 

We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD.  We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our Firm.  Our major suppliers are:

 

Accounting                 Fulvio & Associates L.L.P.         5 West 37th Street, 4th Floor

                                                                                                New York, NY 10018

                                                                                                (212) 490-3113

 

Attorney                      Lehman & Eilen                          50 Charles Lindbergh Boulevard,

                                                                                                Suite 505

                                                                                                Uniondale, NY 11553

                                                                                                (516) 222-0888

 

Financial Institution  First Republic Bank                 1230 Avenue of the Americas

                                                                                                New York, NY 10165

                                                                                                (212) 459-9000

 

Clearing Firm             Southwest Securities, Inc.      1201 Elm Street,

                                                                                                Suite 3500

                                                                                                Dallas, TX 75270

                                                                                                (214) 859-9128

 

We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of the internal or external SBD.  The bank maintaining our operating account is: First Republic, 1230 Avenue of the Americas, New York, NY 10020.  Our contact person is Martin Gibson, (212) 459-9000.  The bank maintaining our Proprietary Account of Introducing Brokers/Dealers (PAIB account) is First Republic, 1230 Avenue of the Americas, New York, NY 10020.  Our contact person is Martin Gibson, (212) 459-9000.  If our banks and other lenders are unable to provide the financing, we will attempt to seek alternative financing from other sources.

 

 

We have contacted our critical counter-parties, such as other broker-dealers or institutional customers, to determine if we will be able to carry out our transactions with them in light of the internal or external SBD.  Where the transactions cannot be completed, we will work with our clearing firm or contact those counter-parties directly to make alternative arrangements to complete those transactions as soon as possible.

 

 

Our Firm is subject to regulation by: FINRA and SEC.  We now file reports with our regulators using paper copies in the U.S. mail, and electronically using fax, e-mail, and the Internet.  In the event of an SBD, we will check with the SEC, FINRA, and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method.  In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

 

In the event of an SDB which disrupts the Internet or other electronic system used for the filing of the Firm’s FOCUS Reports, a “hard copy” of the FOCUS Report should be delivered by the fastest alternate means then available (i.e. by hand, overnight delivery or U.S. mail) to:

 

Karen Davis

Investigator Specialist

FINRA District No. 10

One Liberty Plaza

New York, New York 10006

 

With a copy to:

 

FINRA

P.O. Box 9401

Gaithersberg, Maryland 20898

 

 

We disclose in writing a summary of our BCP to customers at account opening.  We also post the summary on our Web site and mail it to customers upon request.  Our summary addresses the possibility of a future SBD and how we plan to respond to events of varying scope.   In addressing the events of varying scope, our summary (1) provides specific scenarios of varying severity (e.g., a firm-only business disruption, a disruption to a single building, a disruption to a business district, a city-wide business disruption, and a regional disruption); (2) states whether we plan to continue business during that scenario and, if so, our planned recovery time; and (3) provides general information on our intended response.  Our summary discloses the existence of back-up facilities and arrangements. 

 

In the event of a Significant Business Disruption (SBD) our Firm’s policy is to respond by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations and protecting all of the firm’s books and records.

Our plan anticipates two kinds of SBDs, internal and external.  Internal SBDs affect only our Firm’s ability to communicate and do business, such as a fire in our building.  External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption.  Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

Rohit Manocha, Managing Director, a registered principal, is responsible for approving our business continuity plan and for conducting an annual review. 

Conditions permitting, we plan to continue business during an SBD.  If our offices are unavailable due to an SBD we will conduct business out of a back-up location at 60 East 42^nd Street, New York, NY 10165, ℅ Fulvio & Associates, L.L.P., telephone number (212) 490-3113.

 

Our Firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm.  In addition, our Firm will review this BCP annually, on December 1, to modify it for any changes in our operations, structure, business, or location or those of our clearing firm.