Business Continuity Plan

 

            We have developed a business continuity plan that covers the broker-dealer operations of Goodwin Browning & Luna Securities, Inc (GBLS).  It is designed to ensure that GBLS is prepared to continue providing service to our clients in the event that we experience a significant disruption of any kind to our business operations.  The plan addresses business disruptions of varying severity and scope at our headquarters.  It provides for testing at least annually and in response to any material changes affecting our business, and takes into consideration our critical third-party relationships.  Although it is impossible to anticipate every scenario, we believe that our plan will enable us to resume doing business upon the occurrence of those events that are most likely to affect our headquarters and our data centers.

 

                        What follows is a description of how GBLS will respond to the following four types of disruptions: (1) a firm-only disruption, (2) a disruption that affects a single building, (3) a disruption that affects the entire city or business district, and (4) a disruption that affects the entire Southwest region.  We have also included information about how long we expect it to take us to recover from these disruptions.

 

 

            To respond to a disruption that affects only GBLS, such as a computer virus, we have developed an emergency response/crisis management.  This team has, in the past, successfully guided us through disruptions that have affected our operations and has done so through the use of a crisis communications system and through procedures that address life, health, and safety issues; damage assessment; damage mitigation; personnel mobilization; and mission-critical systems.  If this type of disruption takes place, we intend to restore all critical services within one day after the disruption occurs.  However, in light of the various types of disruptions of this nature that could take place, it may take longer for us to resume operations in one or more of the services during any particular disruption.

 

 

            In the event of a disruption that affects GBLS headquarters, such as a fire in the building, our plan calls for a response involving multiple locations.  We will resume critical services by moving key personnel to various locations and, to the extent necessary to our back-up facility.  Certain key personnel may also work remotely by connecting to the network from a remote location.  In addition to relocating key personnel to back-up faculties, we will, if necessary, transfer responsibility for certain operations and support services to our offsite offices.  We intend to resume operations in all of our critical service areas within one day after a disruption of this nature occurs.  It may, however, take as long as two or three days to continue doing business in one or more critical service areas depending on the availability of data a applications from our data centers.

 

 

 

            If a disruption significant enough to affect the entire city of business district, such as a terrorist attack, cuts off access to GBLS headquarters, under our plan we will resume critical services at our back-up facilities and certain GBLS offsite offices.  As above, certain key employees will work remotely and certain operations and support services would be handled by other GBLS offices.  We intend to resume operations in all of our critical service areas within one day after a disruption on the availability of data and applications from our data center and on the availability of key employees.

 

 

            In the event of a disruption that affects the entire Southwest region such as a regional power outage, we will resume critical service areas from back-up facilities and certain of GBLS offsite locations.  Although GBLS intends to resume operations within one day after the disruptions occurs, one or more of our critical service areas may not be able to resume operations until the disruptions is over.

 

            In all of the situations described above, GBLS expects to resume operations within the specified time frames.  However, in the event that a business disruption results in a significant loss of life at our headquarters or otherwise results in our key employees being unavailable or unable to report to their designated back-up facility, the recovery times described above may be significantly increased.  Furthermore, although we expect to continue operating regardless of the type of disruption, it is impossible to anticipate every scenario.  It is, therefore, possible that a significant business disruption could result in GBLS deciding that we are unable to continue doing business.  In those situations, our plan provides procedures to help ensure that our customers have prompt access to their funds and securities.

 

            We are continuing to devote substantial resources to the enhancement of our business continuity plan.  We are continuing to assess how our plan takes into consideration out critical third party relationships.  In addition, we may enter into agreements with other firms to perform certain clearing and services functions on our behalf in the event of a disruption, until we have the capability to resume performing those tasks.  Finally, we are working towards a target point of readiness in which we will be able to resume operations within a time period that is consistent with evolving industry standards even if our key employees are unavailable.

 

            GBLS’s business continuity plan is subject to modification.  We will promptly post information about updates or modifications to the plan on our website.  You can also obtain updated information about the plan by requesting a written copy by mail.  All requests for updated information should be sent to the following address:

 

Goodwin Browning & Luna Securities, Inc.

Attn: John Goodwin

7801 Academy Blvd. NE,

Bldg 2, Ste. 101

Albuquerque, NM  87109

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