BCP Client Disclosure and Acknowledgement
Date: 12/18/2014
Subject: Business Continuity Plans
FINRA Rule 4370
Effective Date: 08/01/2008
Purpose of this disclosure
FINRA Rule 4370 requires member firms to create and maintain a written business continuity and contingency plan and procedures relating to an emergency or significant business disruption (“SBD”)
Firm Policy
In the event of a SBD it is the policy of Cobra Trading, Inc. to react quickly and efficiently and according to pretested and pre-planned procedures to ensure the safety of our employees, associates, customers, as well as critical operational and account data. We will provide information to employees, associates and clients both pre and post SBD to ensure operations are run as smooth as possible during this critical time.
Significant Business Disruption (SBD)
Definitions:
Our firm’s business continuity plan covers three types of disruptions:
• Firm Disruptions (FD) – Includes but are not limited to firm disruptions such as a building fire, a
building power outage, computer or network malfunction or virus infection disruption or disconnection of
telephone services.
• Local Disruptions (LD) – Includes but not limited to local disruptions such as regional floods, fire,
terrorist attack, earthquake, tornado, hurricane, chemical spill or regional power, telephone or internet
outages.
• Regional Disruptions (RD) – Includes but not limited to regional disruptions such as power grid failure or regionally affected natural disaster or terrorist attack.
FD
In the event of a FD, clients can call our alternative location at 612-747-1419 for information and instructions. Under this scenario, Cobra Trading will plan to continue doing business under this scenario with a period of two hours of the FD.
LD
In the event of a LD, clients can call our alternative location at 612-747-1419 or if the secondary location is
effected by the LD, clients can call Clearing Firm Wedbush Securities at (214) 239-7200 or Interactive Brokers at 312.542.6846 for information and instructions. Under this scenario, Cobra Trading will close operations and inform our clients via phone, e-mail or website our recovery time.
RD
In the event of a RD, clients can call our alternative location at 612-747-1419 or if the secondary location is
effected by the RD, clients can call our Clearing Firm, Wedbush Securities at (213) 688-8000 or Interactive
Brokers at 312.542.6846 for information and instructions.
Data Back-up
Cobra Trading, Inc. backs up its critical information and stores this information at a designated off-site location in the event of a destruction of critical documents caused during a SBD.
Plan review and updates
This Business Continuity Plan is subject to change and is modified and tested at least annually for updates and revisions. An updated and current copy of this summary is posted and can be viewed at https://www.cobratrading.com. Clients can also request this document by calling the firm and a copy will be
mailed via U.S mail to the client.