Introduction
Coe Hill Advisors, LLC is dually-registered under both securities and commodity futures legislation. As a Commodity Trading Advisor (CTA), we are also a Member of the National Futures Association (NFA). Although we are not specifically required under securities legislation regulations to establish and maintain a disaster recovery / business continuity plan, NFA Rule 2-38 requires of each NFA Member to establish and maintain a written business continuity and disaster recovery plan that outlines procedures to be followed in the event of an emergency or significant business disruption (SBD). Such plan must be reasonably designed to enable the Member to continue operating, to reestablish operations, or to transfer its business to another Member with minimal disruption to its customers, other Members, and the commodity futures markets.
Our Disaster Recovery / Business Continuity statement is intended to anticipate and plan for SBDs that might occur to our firm-either internal or external. Internal SBDs affect only our firm's ability to communicate and do business, such as fire in our building. External SBDs prevent the operation of the markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale regional disruption. Our firm's response to an External SBD relies more heavily on other organizations and systems, especially on the capabilities of our custodial and clearing firms.
A copy of our business continuity plan (BCP) is available upon request by contacting the firm's Chief Compliance Officer, Kevin Laffey, at +1 (603) 724-6721, e-mail us at info@coehilladvisors.com, or write us at Coe Hill Advisors, LLC, POB 107, Center Harbor, NH 03226, Attention: Kevin Laffey.
Coe Hill Advisors, LLC intends to remain in business despite any form of Significant Business Disruption (SBD). We would expect that we could respond effectively to any Internal SBD (fire, flood, hurricane damage) within a matter of days following any such event. We do not maintain custody of any client assets -whether in our capacity as a securities Registered Investment Adviser or Commodities Trading Advisor. Since no client assets are held by this firm, we are protected to the extent of our external custodians and clearing firms, which are significant business(es) with on and off site redundancy in their accounting, management and other systems. Similarly, our clients are protected by this redundancy in the event of an External SBD (terrorist attack, political disruption, economic disruption).
Our Business Continuity Plan Disclosure Statement stipulates the details of this plan, including alternative physical locations for employees, temporary office space, and customer access to funds, traidng and securities within and with respect to their accounts.
For the purposes of this summary statement, further information can be found at our website at http://www.coehilladvisors.com. Telephone and alternative contact information are as follows: main office phone: +1 (603) 724-6721 (Direct); toll-free number: +1 (866) 370-9512.
Disaster Recovery / Business Continuity Plan
Coe Hill Advisors, LLC (the “Adviser”) has developed a Disaster Recovery / Business Continuity Plan (“DR/BCP”) on how the firm will respond to events that significantly disrupt its business. Since the timing and impact of disasters and disruptions is unpredictable, the firm will have to be flexible in responding to actual events as they occur. With that in mind, the firm’s principals have prepared this information on the firm’s business continuity plan for you to review so that both the Adviser and its clients may be perhaps better informed about what actions to take in the occurrence of any such interruptive events.
Contacting Us –
If after a significant business disruption you are able to contact us as you might usually do at our general office number +1 (603) 724-6721, you may obtain information about your account and engage with any of the firm’s authorized representatives with regards to processing requests or obtaining information related to your account to the extent that we are capable of (the Adviser does not maintain custody of client funds or securities; these are maintained at the securities broker/dealer, futures commission merchant and/or custodial clearing firm where your securities and/or futures brokerage account is located). Should the custodial firm where your funds or securities are held be affected by any adverse event, we may not be capable of assisting you in the capacity of obtaining information about your account or processing requests related to your account; however, we shall endeavor to do so.
In the event for any reason you are unable to contact us and you require immediate assistance regarding the status of your account, you should directly contact the broker/dealer, futures commission merchant and/or custodial clearing firm where your securities and/or futures brokerage account is located. If you retain ability to access the internet, you should also check our website for information we may post there regarding the SBD, estimated recovery times, and other important information.
Our Business Continuity Plan –
The Adviser plans to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our clients to engage with our representatives to process requests and obtain information.
In short, our business continuity plan is designed to permit the firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with clients, employees, and regulators; alternate physical location of employees; critical vendor, supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our clients prompt access to information regarding the status of their account(s) if we are unable to continue our business.
Clearing firms, the respective broker/dealer(s), futures commission merchant(s), or custodian(s) where your securities and/or commodity futures brokerage account(s) may be located, typically back up important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we believe that most clearing firms’ primary objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments within one business day. Your orders and requests for funds and securities could be delayed during this period, however.
Varying Disruptions –
Significant business disruptions (SBDs) can vary in their scope, such as only our firm, a single building housing our firm, the locality area where our firm is located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we shall attempt to transfer our operations to a local site when needed and expect to recover and resume business within one business day. In a disruption affecting our business district, locality, or region, we shall attempt to transfer our operations to a site outside of the affected area, and recover and resume business within a week. In either situation, we plan to continue in business using the alternative methods of communication listed above. If the significant business disruption is so severe that it prevents us from remaining in business, we inform clients of this as soon as possible so that they may promptly make alternate arrangements for management of their funds, trading positions and/or securities held at their broker/dealer, futures commisision merchant or custodian.
If you have questions about the firm’s business continuity planning, you can contact the Chief Compliance Officer, Kevin Laffey, at +1 (603) 724-6721, e-mail us at info@coehilladvisors.com, or write us at Coe Hill Advisors, LLC, POB 107, Center Harbor, NH 03226, Attention: Kevin Laffey.
