Metacortex Services Corporation Business Continuity PlanRevised: March 30, 2009 I. Emergency Contact PersonMetacortex’ emergency contact person is Jimmy Talbot, CEO,
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. The contact person will be updated in the event of a material change, and will be reviewed within 10 business days of the end of each quarter. II. Policy Metacortex’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming perations, protecting all of the firm’s books and records, and allowing our autotrading service to remain operationl. In the event that we determine we are unable to continue our autotrading service, we will inform customers to contact the carrying broker (Interactive Brokers) to access their funds and close their account. A. Significant Business Disruptions (SBDs)Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only Metacortex’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operations of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our carrying broker (Interactive Brokers). B. Approval and Execution AuthorityJimmy Talbot, President, CEO & CCO of Metacortex Services Corporation, a registered principal, is responsible for approving the plan and for conducting the required annual review, and for executing this BCP. C. Plan Location and Access Metacortex will maintain copies of its BCP, the annual reviews, and the changes that have been made to it for inspection, at its head office. III. Business Description
Metacortex conducts business in equity and derivative securities. Our firm is an investment advisor and does not hold client funds or securities. We enter orders in our clients’ accounts which are held with a 3rd party broker. IV. Office LocationThe Metacortex head office is located in Toronto, Ontario. V. Alternative Physical Location(s) of employeesIn the event of an SBD, we will attempt to move staff members from the head office to an unaffected physical location, the location of which depends on the SBD and will be determined at the time. VI. Customer’s Access to Funds and SecuritiesMetacortex does not maintain custody of customers’ funds or securities, which are maintained by our carrying broker, Interactive Brokers. In the event of an internal or external SBD, if telephone service is available, our registered persons will take instructions and contact our carrying broker on their behalf. If our Web access is available, Metacortex will post on our Web site how our customers may access their funds and securities. VII. Data Back-up and RecoveryMetacortex maintains its primary hard copy books and records and its electronic records at its head office. Jimmy Talbot is responsible for maintenance of these books and records. The firm backs up its electronic records daily to an off-site location. In the event of an internal or external SBD that causes the loss of our paper records, we can recover copies electronically from our off-site location VIII. Financial and Operational AssessmentsA. Operational RiskIn the event of an SBD, Metacortex will immediately identify what means will permit us to communicate with our customers, employees, and carrying broker. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our Web site, telephone voice mail, and e-mail. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery. B. Financial and Credit RiskIn the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations. IX. Mission Critical SystemsMetacortex’s “mission critical systems” are those that ensure continuation of its autotrading service. More specifically, these systems include internet access, email access, and at least one computer to run Metacortex’ autotrading platform. Our carrying broker maintains its own business continuity plan which can be accessed on its web site at https://www.interactivebrokers.com/Universal/servlet/Registration_v2.formSampleView?doc=showIBContinuityPlanDisclosure.jsp as of the time of this writing. XIII. Disclosure of Business Continuity PlanMetacortex posts this document on our Web site and emails it to clients upon request. XIV. Updates and Annual Review Metacortex will update this plan whenever there is a material change to our operations, structure, business, or location or to those of our carrying broker. In addition, we will review this BCP annually, to modify it for any changes in our operations, structure, business, or location or those of our carrying broker.
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