Business Continuity Plan
In keeping with good business practices, Ingalls & Snyder LLC has for many years developed, maintained and updated business continuity and contingency plans (“BCP”) to ensure the integrity of our business and the security of client assets.
Pursuant to FINRA Rule 4370, we are required to disclose to our clients how our BCP addresses the possibility of a future significant business disruption (a “SBD”) and how we plan to respond to events of varying scope. Such disclosure must, at a minimum, be made in writing to clients at account opening, be posted on our website and mailed to clients upon request. In compliance with the foregoing requirement, we are providing the following summary plan description; please feel free to contact us if you have any further questions.
Our plan anticipates two kinds of SBDs, internal and external. An internal event, such as a fire within our building, would primarily affect our ability to communicate and conduct business. An external event, such as a terrorist attack or wide-scale regional utilities disruption, would prevent or hinder the operation of the financial markets or a number of brokerage firms. It is our intention to continue our business in either of these scenarios; nevertheless, in the unlikely event that we are unable to do so, our BCP addresses the means by which clients will be able to promptly access their funds and securities.
In addition to our firm’s headquarters in New York City, we maintain two additional operational facilities outside New York City and on different power and communications grids. Such facilities backup our electronic records during each business day on a virtually real-time basis. They are readily accessible by our personnel and serve as redundant recovery facilities with immediate availability. In the event of a SBD, it is our minimum goal to be fully operational not later than the following business morning, but we expect that our recovery time will require less than two hours.
In the event of a SBD, it is our policy to safeguard employees’ lives, protect client and firm property and our books and records, and to preserve our ability to continue to do business. Our BCP addresses all of the foregoing critical issues and is reviewed and amended periodically to address changed assessments of need. A copy of our current BCP summary will be mailed to clients upon request. Should you need to contact us as the result of a SBD, you may telephone our main number (212) 269-7800.
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to download a pdf of our latest Report under SEC Rule 606, Routing of Customer Orders.
For over 80 years, Ingalls & Snyder has respected our clients’ privacy and confidentiality. The following is intended to help you understand how Ingalls & Snyder handles personal information that we collect and when and why Ingalls & Snyder may disclose such information. We consider our relationship with you to be of the highest importance. The manner in which we treat the information you provide us about your personal and financial circumstances is an important part of our relationship.
Ingalls & Snyder does not disclose any nonpublic personal information about our current or former clients to anyone, except as permitted by law or upon specific authorization from you.
In order to provide you with appropriate investment management services and to assist you in achieving your financial goals, we collect nonpublic personal and financial information about you. The types of personal information we collect and share can include, but are not limited to: Social Security Number, income, account balances, transaction history, investment experience, assets, etc. We collect your personal information, for example, when you: open an account, enter into an investment advisory contract, give us your income information, make deposits or withdrawals from your account, or give us your contact information. We also collect your personal information from others, such as credit bureaus, affiliates or other companies.
We protect the security, privacy and use of this confidential information. Ingalls & Snyder employees have access to client information based on their job functions, enabling them to assist you in completing your transactions, maintaining your portfolio and account records and in responding to any questions that might arise. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.
It is necessary for us to share certain information about you and your portfolio or account with service providers that Ingalls & Snyder hires to perform services on our behalf, such as printers, proxy and report forwarding firms or consultants who work on our computer systems. These companies may use this information solely for the contracted services and are not permitted to use or share this information for any other purpose. Ingalls & Snyder may share such information with affiliated entities, such as our private accredited investor funds, only at the request of your Ingalls & Snyder representative. Ingalls & Snyder does not share your personal information for joint marketing with other financial companies or for affiliates and nonaffiliates to market to you.
Governmental agencies, regulatory authorities and other persons, when authorized by law, may have access to such information. As a registered broker-dealer and investment advisor, Ingalls & Snyder is subject to periodic examinations by the Securities and Exchange Commission and securities self-regulatory organizations (“SRO”), such as FINRA. In the context of these examinations and other governmental or SRO investigations, representatives of these organizations may access confidential personal information about you, your portfolio and account. If they request such information, Ingalls & Snyder is required to provide access to your information. We collect personal information about you only to conduct and process your business affairs in the most appropriate, effective and efficient manner, and we have established policies and procedures for the secure destruction of such information when no longer needed. We respect and will continue to protect your privacy.