PICO QUANTITATIVE TRADING LLC
BUSINESS CONTINUITY PLAN DISCLOSURE
Pico Quantitative Trading LLC (“PQT”) has developed a Business Continuity Plan (“BCP”) in the event of a “significant business disruption” (“SBD”), i.e., how we will respond to an emergency or event that significantly disrupts our business. Because the timing and impact of disasters and disruptions is unpredictable, our BCP is by necessity flexible to allow us to respond to actual events as they occur and given the scope and severity of the SBD. With that in mind, we are providing you with this information on our BCP.
PQT’s BCP is designed to notify our Clients of the effect an SBD has on the manner in which they access us and the services that we are providing to them. Our goal is to safeguard our employees’ lives and Firm property, making a financial and operational assessment, quickly recover and resume operations, protect PQT’s books and records, and to meet existing obligations to our Clients.
In the event of an SBD effecting PQT and the services it provides to Clients, and/ or effecting services received by Client from PQT Vendors or Executing Broker(s) (as hereinafter defined), PQT will contact its Clients by the most effective means available including telephone, email, instant message, our Website (www.picotrading.com) or fax.
Presently our clients’ securities orders are directed through third party vendor systems (“Vendors”) to our partner executing broker(s) (the “Executing Broker(s)”) who open accounts, execute, clear and settle (or arrange for the clearance and settlement) of trades for our mutual clients (the “Clients”). The Clients are deemed “customers” of the Executing Broker(s) for the purposes of all applicable laws, including the Securities Investor Protection Act, as amended, and regulations adopted thereunder, and the financial responsibility rules adopted by the Securities and Exchange Commission under the Exchange Act of 1934. PQT does not hold Clients’ funds or securities.
Accordingly, in the event of an SBD, Clients should contact the Executing Broker(s) with whom the Client has opened an account directly to execute their orders, ascertain the Executing Broker(s) “easy to borrow” list and to access their funds and securities.
In terms of provision of reports and other PQT services, in the event of an SBD effecting PQT’s offices, PQT has made provisions for reports and services to continue to be provided via remote locations provided that the Vendors and Executing Broker(s) systems are accessible.
Our Business Continuity Plan addresses the following: alternative physical location(s) of employees, Clients’ access to funds and securities; data back-up and recovery; financial and operational assessments; mission critical systems; alternative communications between PQT and Clients, employees and regulators; critical business constituents (i.e., Vendors and Executing Broker(s)), banks and counterparties.; and regulatory reporting.