At Gagnon Securities LLC (GS), we recognize that you rely on our systems and services for the management of the assets that you have entrusted to us. We also recognize that the unexpected can and does occur – from simple situations to major outages. GS has successfully maintained critical business activities during disruptions of normal business processes and we want you to know that we have an extensive plan in place to safeguard your vital account information in the event of a business disruption of varying scope.
GS has pre-established contingency and disaster recovery plans. Components of this plan are reviewed and tested periodically to ensure effectiveness. GS considers contingency planning to be an ongoing process that requires regular review and assessment of the various risks and appropriate responses. As a result, our plan may change from time to time as necessary. Please feel free to contact Alison Tranchida any time at 212-554-5007 to receive the most updated version of our Business Continuity Plan Summary. In addition, the most recent version of our summary can be found on our web site, www.gagnonsec.com.
Our clearing firm, National Financial Services LLC, a Fidelity Investments® backs up their important records in a geographically separate location. Some of these records contain custodial and settlement records for our clients. While emergency situations may pose unique problems, depending upon time of day and the severity of the disruption, our clearing firm has advised us that its objective is to restore its own operations, be able to complete pending transactions, and accept new transactions within 12 hours. Orders and requests for funds and/or securities could therefore be delayed during this period.
Significant business disruptions can vary in scope. For example, they could affect only our firm; a single building that house our firm; the business district within which we operate; the city in which we are located; or the entire region. Within each of these areas, the severity of disruption can vary from minimal to severe. In a disruption to our firm or a building that houses our firm, we will transfer our operations to a site(s) outside of the affected area, recover and resume business within eight hours by either connecting to our main computer network or our duplicate computer network located outside of New York City that receives regular daily streams of back up data. In any scenario of business disruption we plan to continue our business; if necessary we will transfer our operations temporarily to our clearing firm. We will notify our clients by any means available to us including telephone, e-mail, cell phone, or postings to our web site. If a significant business disruption is so severe that it prevents us from remaining in business, we will assure prompt access to our clients’ funds and securities.
Key features of GS’s Business Continuity Plan include annual reviews of the following:
- Identification of all mission critical systems (and system backup and recovery)
- A review of financial operations and risks
- Alternate communications between GS and our clients, clearing firm, critical business constituents and regulators
- Employee safety strategies and communications
- Alternate computer network location and preparedness