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NatAlliance Securities, LLC
Business Continuity Plan
March 2021 Update
- Emergency Contact Persons
Our firm’s two emergency contact persons are: Mark Salter at 512-609-1720 or msalt@natalliance.com and Alex Hendrickson at 212-379-1078 or ahendrickson@natalliance.com.
The firm will provide FINRA with the contact information for the two emergency contact persons: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile number through the FINRA Contact System (FCS). Mark Salter or his designee will promptly notify FINRA of any change in this information through FCS (but no later than 30 days following the change) and will review, and if necessary update, this information within 17 business days after the end of each calendar year.
- Firm Policy
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. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.
- Significant Business Disruptions (SBDs)
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 firms.
- Approval and Execution Authority
Mark Salter, CEO, a registered principal, is responsible for approving the plan and for conducting the required annual review. Alex Hendrickson has the authority to execute this BCP.
- Plan Location and Access
Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on a disk with a file named “Business Continuity Plan”. One disk will be maintained by the Compliance Department. A second copy will be maintained at the New York office location.
III. Business Description
The Firm’s main business is sales and trading in fixed income securities, including corporate bonds, municipal bonds, government backed securities, and collateralized mortgage obligations. The Firm also engages in the sale of equity securities, primarily to institutional customers.
The Firm is an introducing Firm only. It accepts and enters orders, but it does not hold customer funds or securities. It relies on its clearing firms to compare, allocate, settle, and clear transactions.
The Firm has a contract with one clearing Firm, Hilltop Securities.
Hilltop Securities clears the Firm’s fixed income and equity transactions, and it maintains accounts for the Firm’s customers. Hilltop Securities grants customers access to their accounts and delivers customers’ funds and securities. All equity transactions are conducted on a DVP/RVP basis.
The contact information for Hilltop Securities Inc is:
Hilltop Securities Inc.
1201 Elm Street, Suite 3500
Dallas, TX 75270
214.953.4000
http://www.hilltopsecurities.com/
Our contacts there are:
Chris Cervantes (primary)
214.859.6645
chris.cervantes@hilltopsecurities.com
or
Jonathan Rogers (alternate)
214.859.6871
Jonathan.rogers@hilltopsecurities.com
- Office Locations
Our Firm has the following registered office locations:
- Austin, TX (Main)
NatAlliance’s main office is located 111 Congress Avenue, Suite 800, Austin, TX 78701. Its main telephone number is 512-609-1700. Employees travel to the office by means of mass transit and automobile. This office serves as our home office, and supervisory and administrative functions, such as human resources, accounting, legal, and other executive functions, occur at this location. We also engage in order taking and entry at this location. The office serves as one of the primary areas for operational functions on behalf of the firm.
- New York, NY
This office is located at 54 West 21st St, Ste 801, New York, NY 10010. Its main telephone number is 212-379-1000. Our employees may travel to that office by means of mass transit and automobile. We engage in order taking and entry at this location.
- McQueeny, TX
This office is located at 636 Woodlake Dr, McQueeny, TX 78123. Its main telephone number is 713-706-6136. Employees travel to that office by means of automobile. We engage in institutional and retail sales here.
- Napa, CA
This office is located at 1013 Toldi Ln, Napa, CA 94558. Its main telephone number is 707-637-4042. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
- Chicago, IL
This office is located at 30 S Wacker Dr #2200, Chicago, IL 60606. Its main telephone number is 312-466-5559. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
- Radnor, PA
This office is located at 201 King of Prussia Rd, Ste 650, Radnor, PA 19087. Its main telephone number is 484-590-5159. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
- Jersey City, NJ
This office is located at 2nd St #204, Apt 3, Jersey City, NJ 07302. Its main telephone number is 212-379-1008. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
- Boulder, CO
This office is located at 400 Mapleton Ave, Boulder, CO 80304. Its main telephone number is 212-379-1097. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
- Galveston, TX
This office is located at 8610 Seawall Blvd #D, Galveston, TX 77554. Its main telephone number is 512-609-1725. Employees travel to that office by means of mass transit and automobile. We engage in institutional and retail sales here.
- Boston, MA
This office is located at 50 Congress St, Boston, MA 02109. Its main telephone number is 617-901-2517. Employees travel to that office by means of mass transit and automobile. We engage in investment banking here.
- Charlotte, NC
This office is located at 4201 Congress St, Ste 450, Charlotte, NC 28209. Its main telephone number is 704-551-3700. Employees travel to that office by means of mass transit and automobile. We engage in institutional equity trading here.
- Dallas, TX
This office is located at 7777 Glen America Dr, Ste 353, Dallas, Tx 75225. Its main telephone number is 214-373-3600. Employees travel to that office by means of mass transit and automobile. We engage in institutional equity sales here.
Our Firm has the following unregistered locations:
- Sarasota, FL
This office is located at 5541 Ashton Lake Dr, Sarasota, FL 34231. Its main telephone number is 941-924-4633. This is a private residence. We engage in institutional sales here.
- Greenwich, CT
This office is located at 33B Putman Green, Greenwich, CT 06830. Its main telephone number is 203-249-7454. This is a private residence. We engage in institutional sales here.
- Alexandria, VA
This office is located at 27 Keiths Lane, Alexandria, VA 22314. Its main telephone number is 571-733-3100. This is a private residence. We engage in institutional sales here.
- Union, KY
This office is located at 1209 Citation Dr., Union, KY 41091. Its main telephone number is 859-869-2077. This is a private residence. We engage in retail sales here.
- Booneville, AR
This office is located at 365 Calihan Rd, Booneville, AR 72927. Its main telephone number is 479-675-2788. This is a private residence. We engage in retail sales here.
- Leawood, KS
This office is located at 12843 Cambridge Rd, Leawood, KS 66209. Its main telephone number is 512-609-1709. This is a private residence. We engage in institutional sales here.
- Lakeville, MN
This office is located at 21275 Ridgewood Trl, Lakeville, MN 55044. Its main telephone number is 212-379-1006. This is a private residence. We engage in institutional sales here.
- Atlanta, GA
This office is located at 330 Cumberland Blvd, Ste 353, Dallas, Tx 75225. Its main telephone number is 404-358-2109. This is a private residence. We engage in institutional equity sales here.
- Reston, VA
This office is located at 1931 Crescent Park Dr., Reston, VA 20190. Its main telephone number is 212-379-1079. This is a private residence. We engage in institutional sales here.
- Alternative Physical Location(s) of Employees
In the event of an SBD, we will move our staff from the affected offices to the closest of our unaffected office locations. If none of our other office locations is available to receive the staff, we will move them to other locations based on availability. The firm is at an advantage in that its employees can essentially work from their homes should the situation warrant such a move.
- Customers’ Access to Funds and Securities
Our firm does not maintain custody of customers’ funds or securities. Hilltop Securities maintains all customer funds and securities pursuant to our clearing agreement. In the event of an internal or external SBD, if telephone service is available, our registered persons will take orders or instructions regarding customer accounts and contact Hilltop Securities. If Web access is available, our firm will also post on its website that customers may access their funds and securities by contacting Hilltop Securities at 214-953-4000. The firm will make this information available to customers through its disclosure policy.
If SIPC determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books and records identifying customer accounts subject to SIPC regulation.
VII. Data Back-Up and Recovery (Hard Copy and Electronic)
Our firm maintains its primary hard copy books and records and its electronic records at various locations depending on the type of document. Each branch manager is responsible for the maintenance of certain books and records as outlined in the Firm’s Compliance Manual. Our firm maintains the following document types and forms that are not transmitted to our clearing firm: correspondence, blotter, logs and various documents used to evidence supervision.
Our firm maintains its back-up electronic copy of books and records through undisclosed off-site third-party vendors. These records are maintained on severs stored offsite. Mark Salter is responsible for the maintenance of these back-up books and records. Our firm backs up its paper records by copying and taking them to our back-up site. We back up our records, depending on document type, on a daily, weekly, or monthly basis.
The firm backs up its electronic records daily and weekly by an automated back-up process on our internal server. The information is also backed up to an external server.
In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our back-up site. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.
VIII. Financial and Operational Assessments
- Operational Risk
In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, 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 our web site, telephone voicemail, secure e-mail, etc. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).
- Financial and Credit Risk
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 request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including FINRA District Office in Dallas.
- Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. These systems include Bloomberg (order entry purposes); telephone systems (communications) and our computers (communications, account access and order entry).
We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking, entry, and execution. Our clearing firms provide, through contract, comparison, allocation, clearance and settlement of securities transactions, maintenance of customer accounts, access to customer accounts and the delivery of funds and securities.
Our clearing firms maintain business continuity plans and the capacity to execute those plans. Our clearing firms have represented that they will advise us of any material changes to its plan that might affect our ability to maintain our business. In the event one of our clearing firms executes its plan, it will notify us of such execution and provide us equal access to services as its other customers. If we reasonably determine that our clearing firm has not or cannot put its plan in place quickly enough to meet our needs or is otherwise unable to provide access to such services, our clearing firms will assist us in seeking services from an alternative source.
Our clearing firms have represented that they back up our records at a remote site. Our clearing firms represent that they operate back-up facilities in geographically separate areas with the capability to conduct the same volume of business as their primary sites. Our clearing firms have also confirmed the effectiveness of their back-up arrangements to recover from a wide scale disruption by testing on an ongoing basis.
Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption and status of critical infrastructure—particularly telecommunications—can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption. Our clearing firms have the following SBD recovery times and resumption objectives: recovery time period of within hours and resumption time of within the same day.
Compliance will maintain a copy of the clearing firms BCP disclosures as evidence of periodically reviewing our clearing firm’s capabilities to perform the mission critical functions the clearing firms have contracted to perform for our firm.
- Our Firm’s Mission Critical Systems
- Order Taking
Currently, our firm receives orders from customers primarily via telephone. During an SBD, either internal or external, we will continue to take orders through this and any other methods that are available and reliable. In addition, as conditions permit, we will inform our customers when alternate ways to communicate orders become available. Customers will be informed of alternatives by posting instruction on the website. If necessary, we will advise our customers to place orders directly with our clearing firms.
- Order Entry
Currently, our Firm enters orders electronically into our order management systems—Bloomberg TOMS, FlexTrade, and Knight Direct—which automatically send the orders to our clearing firms. In the event of an internal SBD, we will enter and send records to our clearing firms by the fastest alternative means available, which may include telephone, email, or fax. In the event of an external SBD, we will maintain orders in electronic or paper format, and deliver the orders to the clearing firms by the fastest means available when they resume operations.
- Order Execution
We currently execute orders by sending them to our clearing firms. In the event of an internal SBD, we would search for the best available channel to send orders to our clearing firms. In the event of an external SBD, we would do the same. If we are unable to send customer orders to our clearing firms, we may refer our customers to deal directly with the clearing firms.
- Other Services Currently Provided to Customers
Order execution is the only service we provide customers. We do not hold any customer funds or securities.
- Mission Critical Systems Provided by Our Clearing Firm
Our firm relies, by contract, on our clearing firms to provide order execution, order comparison, order allocation and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.
- Alternate Communications Between the Firm and Customers, Employees, and Regulators
- Customers
We now communicate with our customers using e-mail, Bloomberg, telephone, fax, U.S. mail, and in person visits at our firm or at the other’s location. 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 will contact them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.
- Employees
We now communicate with our employees using telephone, fax, e-mail, US Mail, express delivery 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. 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 (see Attachment A).
- Regulators
We are currently members of the FINRA, MSRB and SIPC. 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 the other party.
- Critical Business Constituents, Banks, and Counter-Parties
- Business Constituents
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. The Firm currently has no major suppliers at this time.
- Banks
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:
Plains Capital Bank
325 N. Saint Paul St., Ste 800
Dallas, Tx 75201
Direct Phone: (866) 762-8392
Website: plainscapitalbank.com
Our Proprietary Account of Introducing Brokers/Dealers (PAIB account) is maintained at Hilltop Securities.
- Counter-Parties
We have contacted our critical counterparties, 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 counterparties directly to make alternative arrangements to complete those transactions as soon as possible.
XII. Regulatory Reporting
Our firm is subject to regulation by FINRA, MSRB and the 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, MSRB 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.
FINRA – District 6 MSRB
12801 North Central Expressway 1300 I Street NW, Ste 1000
Suite 1050 Washington, DC 1000
Dallas, TX 75243-1778 (202) 838-1500
(972) 701-8554
Fax: (972) 716-7646
Securities and Exchange Commission
Fort Worth Regional Office Burnett Plaza, Suite 1900 801 Cherry Street, Unit 18 Fort Worth, TX 76102 (817) 978-3821
XIII. Disclosure of Business Continuity Plan
Attached is the written BCP disclosure statement that our clearing firm provides to customers at account opening and annually (See Attachment B). We also post the disclosure statement on our website and mail it to customers upon request.
XIV. Updates and Annual Review
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 as part of the CEO certification process required by supervisory controls rules and regulations, to modify it for any changes in our operations, structure, business or location or those of our clearing firm.
- Senior Manager Approval
I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.
Signed: _______________________________
Mark Salter
Title: CEO
Date: