Gleacher & Company, Inc. (and its subsidiaries) is responsible for creating and maintaining business continuity plans to support services to its customers. In the event of a business disruption, we have plans designed to continue operations of critical business functions, including the execution and processing of institutional orders to our clearing firms, Pershing, LLC, Ridge Clearing and Outsourcing Solutions, The Bank of New York Mellon, and JP Morgan Clearing Corporation.
Our business continuity plan encompasses business disruptions that may be internal to Gleacher & Company, and larger wide-spread disruptions that effect entire regions. Business disruptions affecting a single branch or office will likely result in the closure of the office for the duration of the interruption and all communications being re-routed to one of Gleacher & Company's other offices as quickly as possible. Regional interruptions would also involve the closure of affected offices and the re-routing of communications to one or more of Gleacher & Company's primary office locations. A large scale disruption would also involve the relocation of staff to assist in restoring operations. Should there be a significant business disruption, customers are encouraged to visit Gleacher & Company's Web site (www.gleacher.com) for additional information.
Our plan is designed to address key areas of concern, including but not limited to the following:
Data (electronic and hard-copy) back-up and recovery;
Alternate communication between the firm and customers;
Alternate communication between the firm and employees;
Alternate locations for employees;
Identification of mission critical systems;
Regulatory reporting and communications;
Identification of critical business constituent, bank and counter-party relationships;
Financial and operational risk assessments;
Ensuring customers access to cash and securities in the event Gleacher & Company is unable to continue business.
Gleacher & Company has been supplied with a summary of our clearing firm's business continuity plans. Funds and securities of institutional clients are not held by Gleacher & Company. The majority of institutional transactions are processed delivery versus payment and receipt versus payment.
Although Gleacher & Company has taken steps to develop and implement business recovery plans, we cannot guarantee that systems will always be available or recoverable after a disaster or significant business disruption. However, we believe that our planning and continued training and testing will provide an effective response and recovery effort in the event of a business disruption.
Our business continuity plan will be reviewed, updated and tested as needed but at least on an annual basis. Additionally, we will continue to test our critical business systems and services provided by outside service agents.
Any material changes to the above information will be available on our web-site www.gleacher.com or upon request.