P
    ProFuturesTrader

    Business Continuity and Disaster Recovery Plan (BCDR)

    Purpose

    In the rare event that ProFuturesTraders' phone systems, internet, and critical functions shut down, you can call directly to StoneX at 1-800-920-5808 or IronBeam at 312-765-7200. However, we do have a backup office in Elizabethtown, KY.

    1. Essential Components (per NFA Interpretive Notice 9052)

    Backup Facilities & Systems

    Primary location: Wilmington, NC. Alternate: Elizabethtown, KY.

    Data & Document Backup

    Periodic backups of essential records (client data, trade logs) are stored in the Google Cloud via Vault and a separate hard drive.

    Third-Party Impact Mitigation

    Assess vendor risks; maintain SLAs and alternative providers (e.g., clearing firms, data feeds).

    Communication Plan

    Procedures to contact: APs, clients, carrying brokers/FCMs, vendors, regulators (NFA/CFTC), and disaster recovery specialists. Use email, secure portal, phone tree.

    2. Plan Activation & Incident Response

    Activation: By Incident Commander (e.g., CEO) or delegate upon major disruption.

    Incident Management Contact (IMC):

    Drew Rathgeber, President 949-996-4611

    Steps: Detect → Assess → Activate → Recover → Test/Stand down.

    3. Regulatory Notifications

    • Update NFA with current key management/disaster recovery contacts (via Member Questionnaire/WinJammer™).
    • Notify NFA/CFTC promptly in emergencies (per Rule 2-38(b) for applicable members).

    4. Testing & Training

    Annual testing

    5. Appendices (Maintained Separately)

    Contact lists (employees, vendors, regulators).

    6. Futures Clearing Merchants (FCMs)

    This streamlined BCDR is a living document tailored to ProFuturesTrader's size, operations, and risks (e.g., hurricane exposure in Wilmington, NC). For questions, contact ProFuturesTrader at 949-996-4611 or email Drew Rathgeber at drathgeber@profuturestrader.com.