Triton

Business Continuity Plan

MidAmerica Financial Services, Inc.

MidAmerica Financial Services, Inc ("MFSI") has developed a Business Continuity Plan ("BCP") on how we will respond to events that significantly disrupt our business. Since the timing and the impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.

MFSI's Business Continuity Plan

The Business Continuity Plan MFSI has adopted enables the prompt resumption of its operations in the event of disruption that affects MFSI or any locality or region in which MFSI operates. MFSI's Business Continuity Plan is designed to enable MFSI to continue or resume its operations as quickly as possible so the firm can provide customers with access to their accounts and to the securities markets. The Plan includes relocation of personnel to pre-assigned alternate facilities if necessary.

In the face of any disaster, MFSI and its employees are committed to providing the firm's customers with access to as full a range of services as is feasible under the circumstances. If possible, MFSI will continue its business operations. In the even of a disruption, MFSI will resume operations as soon as it can do so. MFSI has taken a number of steps to accomplish this, including the establishment of alternate facilities and methods of communication to enable customers to access their accounts and to stay informed about the disruption and resumption of MFSI's business.

Contacting MFSI

If after a Significant Business Disruption you are unable to contact your Registered Representative or our home office as you normally would by phone at: 417-623-9500 or by e-mail at clientservices@mfsinvest.com, you should go to our website at MFSInvest.com for information on how to contact us. If you are not able to access us through any of those means, you should contact our clearing firm, Legent Clearing at (866) 774-0218 for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade related, cash, and security transfer transactions for you.

SRB Capital

​SRB has developed the following business continuity/disaster recovery plan. It is intended to provide business continuation in the event of a natural disaster such as hurricanes, earthquakes, and floods, as well as disasters caused by terrorists. The plan provides for backup of critical information as well as alternative contact means for appropriate personnel.

Introduction

SRB believes that disaster recovery and business continuity issues are of utmost importance and have taken a proactive approach to ensure that the Company has an adequate disaster recovery plan in place. The need for the Company to provide services to our customers in the event of a business disruption is vital, as is the importance that third-parties can contact the Company personnel in the event of an emergency.

Accordingly, the Company has implemented the following plan, as required by NFA Compliance Rule 2-38 and NFA Interpretive Notice 9052, to ensure business continuity in the event of a disaster or business interruption.

Backup Facilities
  • SRB Capital is a registered Independent Introducing Broker with the National Futures Association which currently has clearing relationships with Rosenthal Collins Group, LLC, R.J. O’Brien and Associates LLC, Penson Futures LLC, Vision LLC, Mizuho USA, INTL FC Stone, and RBC Capital Markets. SRB has a branch office located in La Jolla, CA. The branch location is 1020 Prospect St., Suite 405, La Jolla, CA 92037. In a disaster situation affecting the La Jolla office, the first line of business continuity would be the ability of the office to move to a remote site. Jay Ramey is the branch manager and compliance officer of SRB in California. Jay Ramey’s home and office will serve as the backup office location. The office would be used for client contact and trade entry purposes. Mr. Ramey’s’ home office uses one (1) internet connection; one (1) fax line, cell phone service, and has access to remote desk top assistance to view customer data. Also, client contact information such as names, addresses, account activity, and equity statements can be obtained from FCM partner websites in real time. All associates of SRB Capital will be notified by phone in case of disaster. All client information for the client branch is held by the main office and the offices of the respective FCM clearing partners.

In the event the SRB main office becomes unavailable to conduct operations, the Company has designated the following working backup facility, located in a separate geographical location, where firm personnel can and currently conducts business activities:

Address: 440 S. Grant St.

Address: Hinsdale, IL 60521

Telephone #: 630-234-0676

The Company has installed a backup computer system at this location and can be used in the event of an emergency. Further, this location is located in a different power grid and utilizes a different telecommunication vendor than the main office. In addition, the Company shall backup pertinent computer files, essential documents and data on a routine basis to a storage drive. All backup data storage devices shall be maintained at the backup facility.

  • Copies of vital paper documents are maintained on file at the backup facility.

  • A listing of customer contact information, including names, phone numbers, and electronic mail addresses are maintained at the backup facility. All existing customers, FCM personnel, service providers and applicable third-parties have been provided with the alternate phone number and location identified above.

  • This plan will be provided to all key employees of the Company and copies of the plan will be made readily available to all employees upon request. Additionally, a copy of the plan is maintained on file at the backup facility identified above.

    In the event the plan is updated or modified, the Company will ensure that the edited plan is distributed to key employees and that all other employees are notified of changes to the plan.

Implementation of Disaster Recovery/Business Continuity Plan

  • In the event of a business disruption, the Company shall notify all of its customers of the disruption to the company’s operations as soon as practically possible.

  • All customers have been provided with contact numbers at the FCM carrying their account in the event SRB personnel cannot be reached. Numbers provided include order departments, clearing departments, compliance departments, and client services.

Disruptions of Third-Parties

The Company has considered the impact of possible disruptions on behalf of third parties such as the FCMs and compliance/accounting companies that conduct business with the Company. The Company obtains reasonable assurance that the third parties have a disaster recovery/business continuity plan in place.

Annual Testing

The Company will test its disaster recovery/business continuity plan on an annual basis. The Company will maintain written evidence that the plan was tested as well as the results.

Communication with the National Futures Association

The Company has provided the National Futures Association with emergency contact information for individuals who are authorized to communicate with the National Futures Association in the event of an emergency (Note: This information can be updated via the NFA annual questionnaire accessible on the National Futures Association web-site: https://www.nfa.futures.org).