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E
MPIRE
S
ECURITIES
C
ORPORATION
B
USINESS
C
ONTINUITY
P
LAN
(BCP)
I. Emergency Contact Persons
Our firm’s two emergency contact persons are: Jamie Bennett: 310-640-8902, jamie@empiresecurities.com and
Todd Hough: 818-536-4990, todd@empiresecurities.com
. Thesenames will be updated in the event of a material change, and our Executive Representative will reviewthem within 17 business days of the end of each quarter.Rule: FINRA Rule 3520.a
II. Firm Policy
Our firm’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 resumingoperations, protecting all of the firm’s books and records, and allowing our customers to transactbusiness. In the event that we determine we are unable to continue our business, we will assurecustomers prompt access to their funds and securities.A. Significant Business Disruptions (SBDs)Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’sability to communicate and do business, such as a fire in our building. External SBDs prevent theoperation of the securities markets or a number of firms, such as a terrorist attack, a city flood, ora wide-scale, regional disruption. Our response to an external SBD relies more heavily on otherorganizations and systems, especially on the capabilities of our clearing firm.B. Approval and Execution AuthorityJamie Bennett, President, a registered principal, is responsible for approving the plan and forconducting the required annual review and has the authority to execute the/this BCP.C. Plan Location and AccessOur firm will maintain copies of its BCP plan and the annual reviews, and the changes that havebeen made to it for inspection. An electronic copy of our plan is located on Empire server in theBCP folder and in the BCP Repository Service offered by FINRA.
III. Business Description
Our firm conducts business in equities, mutual funds, variable annuities, direct participation programs andprivate placements. Our firm is an introducing firm and does not perform any type of clearing function foritself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders.All brokerage transactions are sent to our clearing firms, which executes our orders, compares them,allocates them, clears and settles them. Our clearing firms also maintain our customers’ accounts, cangrant customers access to them, and delivers funds and securities.Our brokerage clearing firm is Wedbush Morgan Securities, 1000 Wilshire Blvd., Los Angeles, CA 90017,213-688-4568, www.wedbush.com and our contact person at that clearing firm is Eve King, 213-688-4568, eve.king@wedbush.com. Our clearing firm has also given us the following alternative contact inthe event it cannot be reached: Dan Gilkerson, 213-688-8000,danielle.gilkerson@wedbush.com.Our RIA clearing firm is Charles Schwab, 3133 East Camelback Road , Phoenix, AZ. 85016, and ourcontact person at that clearing firm is Michelle Young, 602-355-8207 option 3,
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sales.national@schwabinstitutional.com. Our RIA clearing firm has also given us the following alternativecontact in the event they cannot be reached: Matt Adams 1-800-435-4000,sales.national@schwabinstitutional.com.
IV. Office Locations
A. Office Location #1Our Location #1 Office is located at 1960 East Grand Avenue Suite 555, El Segundo, Ca. 90245.Its main telephone number is 310-640-8902. Our employees may travel to that office by means offoot, car, subway, train, bus, boat or plane.
V. Alternative Physical Location(s) of Employees
In the event of an SBD, we will move our staff from affected offices to the closest of our unaffected officelocations. If none of our other office locations is available to receive those staff, we will move them to3625 Del Amo Blvd., Suite 185, Torrance, Ca. 90503. Its main telephone number is 310-525-0043.Rule: FINRA Rule 3510(c)(6).
VI. Customers’ Access to Funds and Securities
Our firm does not maintain custody of customers’ funds or securities, which are maintained at our clearingfirms, Wedbush Morgan Securities and Charles Schwab. In the event of an internal or external SBD, iftelephone service is available, our registered persons will take customer orders or instructions andcontact our clearing firms on their behalf, and if our Web access is available, our firm will post on our Website that customers may access their funds and securities by contacting Jamie Bennett at 310-640-8902or Todd Hough at 818-536-4990. The firm will make this information available to customers through itsdisclosure policy.Rules: FINRA Rule 3510(a); Securities Exchange Act Rule 15c3-1; 15 U.S.C. 78eee (2003).
VII. Data Back-Up and Recovery (Hard Copy and Electronic)
Our firm maintains its primary hard copy books and records and its electronic records at 1960 East GrandAvenue Suite 555, El Segundo, CA. 90245. Jamie Bennett is responsible for the maintenance of thesebooks and records. Our firm maintains the following document types and forms:
New account forms
Privacy Disclosure statements
Purchase and Sales Blotters…various other blotters
Copies of new business applications, subscription agreements, etc.
Personnel records, U-4s and U-5s and BD forms etc.
Written Supervisory Manual
FINRA Manuals
Accounting information including focus reports, etc.Our firm maintains its back-up hard copy books and records at Firm’s main office. These records consistof the firm’s internal accounting records, subscription agreements and paper copies. These records arealso maintained electronically at the backup site located at 762 Keough St. Bishop, Ca. 93514. JasonBrown of The Jaspen Corporation, a third party vendor, 760-258-0755, is responsible for the maintenanceof these back-up books and records. If our primary site is inoperable, we will continue operations from
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the back-up site or an alternative location. For the loss of electronic records maintained at the Firm’smain office, we well physically recover the hard copy data from our primary site.Rule: FINRA Rule 3510(c)(1).
VIII. Financial and Operational Assessments
A. Operational RiskIn the event of an SBD, we will immediately identify what means will permit us to communicatewith our customers, employees, critical business constituents, critical banks, critical counter-parties, and regulators. Although the effects of an SBD will determine the means of alternativecommunication, the communications options we will employ will includewww.empiresecurities.com, 310-640-8902 voice mail. In addition, we will retrieve our key activityrecords as described in the section above, Data Back-Up and Recovery electronically.The financial and operational risks in the event of an internal SBD are not great. The firm’sassets are substantially all allowable, as defined by SEC Rule 15c3-1 and consist of cash in FDICinsured bank accounts. The internal accounting records needed to maintain the business arelocated offsite. We do not foresee that an internal SBD would significantly impair its ability toconduct business from a financial or operational standpoint. This information will be reviewedand the BCP amended as necessary on an annual basis or at any time that circumstancesdictate.Rules: FINRA Rules 3510(c)(3) & (f)(2); Securities Exchange Act Rule 15c3-1.B. Financial and Credit RiskIn the event of an SBD, we will determine the value and liquidity of our investments and otherassets to evaluate our ability to continue to fund our operations and remain in capital compliance.We will contact our clearing firm, critical banks, and investors to apprise them of our financialstatus. If we determine that we may be unable to meet our obligations to those counter-parties orotherwise continue to fund our operations, we will request additional financing from our bank orother credit sources to fulfill our obligations to our customers and clients. If we cannot remedy acapital deficiency, we will file appropriate notices with our regulators and immediately takeappropriate steps.Rules: FINRA Rules 3510(c)(3), (c)(8) & (f)(2).
IX. Mission Critical Systems
Our firm’s conduct business is exclusively in are those that ensure prompt and accurate processing ofsecurities transactions, including order taking, entry, execution, comparison, allocation, clearance andsettlement of securities transactions, the maintenance of customer accounts, access to customeraccounts, and the delivery of funds and securities.Our clearing firm represents that it backs up our records at a remote site. Our clearing firm represents thatit operates a back-up operating facility in a geographically separate area with the capability to conduct thesame volume of business as its primary site. Our clearing firm has also confirmed the effectiveness of itsback-up arrangements to recover from a wide scale disruption by testing and it has confirmed that it testsits back-up arrangements annually.
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