BUSINESS CONTINUITY

InspereX LLC and Incapital Distributors LLC (collectively, “InspereX/Incapital”) are registered broker-dealers that underwrite and/or distribute fixed income securities, structured notes and preferred stock through a wide range of broker-dealers, banks, investment advisors and other financial institutions.  InspereX/Incapital does not directly conduct business with retail investors.

We are committed to safeguarding the interests of our clients in the event of an emergency or significant business disruption and as such this Business Continuity Plan Disclosure (the "BCP") summarizes InspereX’s/Incapital’s effort to mitigate risks inherent with unforeseen business interruptions. 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, protecting all of the firm’s books and records, and allowing our customers to transact business.   This BCP is also intended to comply with the rules promulgated under FINRA, specifically FINRA Rule 4370.

OVERVIEW

InspereX/Incapital maintains multiple facilities where our trading, sales, operations and information technology infrastructure may reconstitute in the event of a SBD. These facilities are located in various geographic locations, which are far enough apart to diminish risks posed by local disruptions. This separation is a key element of the Firm’s overall business continuity strategy and will allow us to mitigate risks related to specific regional disruptions, a city-wide business disruption or a disruption effecting one building.

In the event of an SBD, the Firm will assess the overall impact of the disruption on the Firm’s business with a goal of recovering and resuming operations as quickly as possible. Our Plan addresses the following areas: (i) data back-up and recovery; (ii) all mission critical systems; (iii) financial and operational assessments; (iv) alternate communications between the Firm and its employees; (v) alternate physical location of employees; (vi) critical vendors and other business contacts; (vii) regulatory reporting; and (viii) communications with regulators.

Significant business disruptions may vary in scope. For example, a disruption may affect only the Firm, the building in which the Firm is located, the business district where the Firm is located or an entire region. Further, the impact of the disruption may also vary from minimal to severe. The extent and severity of the disruption will determine the steps taken by the Firm.

If a disruption only affects the Firm and is minimal, the Firm may conclude that it is not necessary to transfer operations to another location. If, on the other hand, a severe disruption affects the entire region, it is more likely that the Firm will attempt to transfer its operations to a site outside the affected area.

In a disruption to only our firm or a building housing our firm, we will endeavor to transfer our operations to unaffected locations and to resume business within 4 hours, as operations are redundant at our branch office locations.  We will notify you of disruptions via our website www.inspereX.com or our customer emergency number, 262-564-6410 which will provide additional details regarding how to contact us and obtain services or information. If the significant business disruption is so severe that it prevents us from remaining in business, we will endeavor to assure our customer’s prompt access to their funds and securities. 

CONTACTING US - CUSTOMER EMERGENCY HOTLINE 262.564.6410

If after a significant business disruption you cannot contact us as you usually do at 312.379.3700, you should call our alternative number 561.361.1100 or go to our website at www.inspereX.com for additional information.

EMPLOYEE & CLIENT COMMUNICATIONS

The safety of our employees is an essential concern. In the event of an emergency or significant business disruption, the Firm will communicate with its employees in several different ways, which may include a combination of general broadcasts and/or direct individual outreach. Alerts and other information, such as office closures and operating hours, may be posted on the Firm’s internal and/or external websites, phone recordings, automated email responses, and the like. Additionally, the Firm’s senior managers will be contacted directly via a prescribed alert process. In the event of an emergency or significant business disruption, clients may obtain information regarding operating status, order entry alternatives and alternative contact information via the Firm’s website, www.inspereX.comwww.bondnav.com or www.incapnet.com.

BACK-UP LOCATIONS

InspereX/Incapital maintains redundant technology and locations that allow for the reconstitution of trading and operations. In the event that one facility fails, we are able to relocate certain personnel and systems to the backup site or other remote work locations. The backup site is designed to be fully operational at all times. It is equipped with workstations that have redundant computer network connectivity, telephones, printers, fax machines, and other systems specifically necessary for trading and operations. The functionality of the backup systems and facility is routinely tested pursuant to the Firm’s procedures.

FOR MORE INFORMATION

If you have questions about our business continuity planning, you can contact us at [email protected] or contact InspereX LLC’s Head of Strategic Initiatives at 561.361.1100.

DISCLAIMER

The Firm’s business continuity strategy is designed to enable us to meet our existing obligations to our clients even in the event of an emergency or significant business disruption. However, as with any business continuity plan, it is not infallible as these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption. The Firm’s BCP is subject to change without notice. A summary update of this plan may be requested when applicable.

InspereX LLC and Incapital Distributors LLC, 200 South Wacker Dr., Suite 3400, Chicago, IL 60606. Phone: 312.379.3700.