Business Continuity Plan (“BCP”)

BUSINESS CONTINUITY PLAN (“BCP”) 

For Trade-PMR, Inc. and Portfolio Management & Research, Inc.

October 1, 2024

Trade-PMR has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan. Not all elements of the plan are displayed for privacy and other security considerations.

Contacting Us – If, after a significant business disruption, you cannot contact us as you usually do at 888-723-3767, you should call our alternative number 352-332-8723 or go to our web site at https://www.tradepmr.com/. If you cannot access us through either of those means, you should contact our clearing firm, Wells Fargo Clearing Services, LLC., at 877-496-3223 or https://www.wellsfargoclearingservicesllc.com/ for instructions on how they may provide access to funds and securities or enter orders on your behalf.

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.

We back up our important records in geographically dispersed locations. We have been advised by our clearing firm that it also has systems and procedures in place to restore its own operations and be able to complete existing transactions and accept new transactions and payments in a timely manner. A copy of Wells Fargo Clearing Services’ BCP policy is available on their web site, https://www.wellsfargoclearingservicesllc.com/. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, the objective is to restore our operations and be able to complete existing transactions and accept new transactions as soon as possible. Our BCDR Plan is tested every three months and annually reviewed by an independent third-party auditor.

Varying Disruptions – Significant business disruptions can vary in scope, affecting just our firm, a single building, the business district, the city, or even the entire region. The severity of these disruptions can range from minimal to severe. In the event of a disruption that impacts only our firm or its building, we will relocate our operations to a local site or to our clearing firm, as needed, to ensure continuity. If the disruption affects the business district, city, or region, we will also transfer operations to our clearing firm until we can fully recover.

We will keep you informed of any significant business disruptions through our website, https://www.tradepmr.com/, or via a customer emergency number that will provide details on how to reach us. If a disruption is severe enough to jeopardize our ability to remain in business, we will ensure that our customers have prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at 888-723-3767 or compliance@tradepmr.com.