Business Continuity Plan

Commerce Brokerage Services, Inc. (CBSI) has developed a Business Continuity Plan in accordance with the U.S. Securities and Exchange Commission (SEC) NASD Rule 3500 Series requiring members to establish Emergency Preparedness Plans and Procedures. Our Business Continuity Plan provides you with information on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions are unpredictable, we will have to be flexible in responding to actual events as they occur.

Contacting Us

If after a significant business disruption you cannot contact us as you usually do at
800-772-7283 or 800-356-1606, you should call our customer emergency number at
314-290-5006 or go to our web site at www.commercebank.com/brokerage. If you cannot access us through any of those means, you should contact our clearinghouse firm, National Financial Services LLC at 617-563-5977 for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.

Our Business Continuity Plan

We plan 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 customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearinghouse firm, National Financial Services LLC, backs up our 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 have been advised by our clearinghouse firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments with minimal down time. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are 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 will transfer our operations to a local site when needed and expect to recover and resume business within 2 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 48 hours. In either situation, we plan to continue in business, transfer operations to our clearinghouse firm if necessary, and notify you through our web site, www.commercenbank.com/brokerage or our customer emergency number
at 314-290-5006. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities.

For more information

If you have questions about our business continuity planning or would like to receive a written copy via mail, you can contact us at 800-772-7283 or email us through www.commercebank.com/brokerage

 

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