In keeping with good business practices, Wellington Shields & Co. maintains and updates a business continuity plan (“BCP”) to ensure the integrity of our business and the security of clients’ assets. Pursuant to FINRA Rule 4370, we are required to make available to our clients how our BCP addresses the possibility of a future significant business disruption (“SBD”) and how we plan to respond to such events. The BCP 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 BCP description; please feel free to contact us if you have any further questions.
We have categorized “SBD” events into two classes – internal and external events. Internal SBD’s affect only our firm’s ability to communicate and do business, such as a systems problem affecting our firm or a fire in our building. External SBD’s 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 and outside vendors.
Should WSC ever experience an internal SBD where we would not be able to access our New York location, we maintain additional offices outside the NYC area. These branch offices have data and voice communication lines that will allow us to conduct business in a near normal manner. In the event of a SBD we anticipate being operational at these facilities within as little as two hours, and in any event, no later than the next business day. General information regarding our intended responses would be communicated to clients via the fastest available means, including phone, cellular phone, e-mail, or our website.
With regard to the pandemic, WSC has returned to having most mission-critical staff onsite, however, some employees continue to work from home. If WSC ever experiences an external SBD, such as a terrorist attack, a city flood, or a wide-scale regional disruption that would prevent the operation of the securities markets or a number of firms, our intent would be to operate from any branch offices or residences of officers and key employees not affected by the disruption. WSC uses the services of a number of critical vendors, and our ability to operate subject to an external SDB would depend upon the availability of our vendors or alternate vendors. These providers, such as our clearing agent and order management systems, have robust BCP plans and would expect to continue operations via the Internet. It is the intent of WSC to continue operations during an external SBD. We anticipate recovery time from one full business day to as much as one full business week, depending upon the severity of the disruption. Orders and request for funds and securities could be delayed during such a disruption.
During a significant business disruption, WSC will re-establish phone contact with our clients as quickly as possible. Our clients should check our website at www.wellingtonshields.com for our latest information.
As a client of Wellington Shields, we recognize you may need access to your account to sell a position or request a check before we re-establish telephone service. During this time, First Clearing1, our clearing firm, will assist you with sell/liquidation orders and provide check disbursements, if needed. If our firm has declared an emergency and you cannot contact us, please call First Clearing for assistance at 877-496-3223.
This plan is subject to modification. Any updated summary will be promptly posted on our website at www.wellingtonshields.com. Customers may also obtain an updated hardcopy BCP upon request by contacting us at 212-320-3000.
1First Clearing is a trade name used by Wells Fargo Clearing Services, LLC, Member SIPC, a registered broker-dealer and non-bank affiliate of Wells Fargo & Company.