Carrano Financial Planning, LLC

Business Continuity Plan

CRD # 287989

 

 

 

Emergency Contact Persons

Emergency Contact Persons

 

Our firm’s emergency contact person is:

 

Joseph Carrano

925-457-0275

joecarrano8@gmail.com

 

The firm will provide FINRA with the contact

information for the emergency contact

person: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile number through the FINRA Contact System (FCS).

 

Joseph Carrano will promptly notify FINRA of any change in this information through FCS (but no later than 30 days following the change) and will review, and if necessary update, this information within 17 business days after the end of each calendar year.

 

Rule: FINRA Rule 4370(f); FINRA Rule 4517

 

I. Firm Policy

I. 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 resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.

A. Significant Business Disruptions (SBDs)

A. Significant Business Disruptions (SBDs)

 

Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation 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 clearing firm.

 

B. Approval and Execution Authority

B. Approval and Execution Authority

 

Joseph Carrano, CEO, a registered principal, is responsible for approving the plan and for conducting the required annual review. Joseph Carrano, CEO has the authority to execute this BCP.

 

C. Plan Location and Access

C. Plan Location and Access

 

 

Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on GOOGLE DRIVE in the folder named COMPLIANCE.

 

Rule: FINRA Rule 4370(b), (d) and (e).

 

II. Business Description

II. Business Description

 

Our firm conducts business in equity, fixed income, and derivative securities. Our firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders. All transactions are sent to our clearing firm, which [executes our orders,] compares them, allocates them, clears and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services only retail customers. We do not engage in any private placements.

 

Our clearing firm is Shareholders Service Group |

9845 Erma Road, Suite 312 | San

Diego, CA 92131 |

(800) 380-7370

info@ssginstitutional.com |

https://www.ssginstitutional.com/ and our contact person at that clearing firm is

Barry Boyte | (858) 530-1031 | bboyte@ssginstitutional.com

 

III. Office Locations

III. Office Locations

 

Our office is located at 1616 Placer Drive, Concord, CA 94521. Its main telephone number is 925-457-0275. Our employees may travel to that office by means of foot, car, train and bus. We engage in order taking and entry at this location.

 

IV. Alternative Physical Location(s) of Employees

IV. Alternative Physical Location(s) of Employees

 

In the event of an SBD, we will move our staff from our home office to a nearby office that offers a month to month leasing option.

 

Rule: FINRA Rule 4370(c)(6).

 

V. Customers' Access to Funds and Securities

V. Customers' Access to Funds and Securities

 

Our firm does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm, Shareholders Service Group. In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our clearing firm 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 Shareholders Service Group at (800) 380-7370. The firm will make this information available to customers through its disclosure policy.

 

Rules: FINRA Rule 4370(a); Securities Exchange Act Rule 15c3-1; see also

15 U.S.C. §78eee.

VI. Data Backup and Recovery (Hard Copy and Electronic)

VI. Data Backup and Recovery (Hard Copy and Electronic)

 

Our firm maintains its primary hard copy books and records and its electronic records at 1616 Placer Drive, Concord, CA 94521. Joseph Carrano | CEO | 925-457-0275 is responsible for the maintenance of these books and records. Our firm maintains its back-up books and records on GOOGLE DRIVE. The firm backs up its electronic records daily. In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from GOOGLE DRIVE. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location.

 

Rule: FINRA Rule 4370(c)(1).

VII. Financial and Operational Assessments

VII. Financial and Operational Assessments

 

A. Operational Risk

 

In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter-parties and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our company website | https://carranofinancial.com | our company phone number |925-457-0275 | and company email | info@carranofinancial.com|. In addition, we will retrieve our key activity records as described in the section above, Data Backup and Recovery (Hard Copy and Electronic).

 

Rules: FINRA Rules 4370(c)(3),(c)(4), (c)(5), (c)(7), (c)(9 & (g)(2)).

B. Financial and Credit Risk

 

In 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 and remain in capital compliance. We will contact our clearing firm, critical banks and investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps.

 

Rules: FINRA Rules 4370(c)(3), (c)(8) & (g)(2).

VIII. Mission Critical Systems

VIII. Mission Critical Systems

 

Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts and the delivery of funds and securities. We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking and order entry. Our clearing firm provides, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, maintenance of customer accounts, access to customer accounts and the delivery of funds and securities. Our clearing firm contract provides that our clearing firm will maintain a business continuity plan and the capacity to execute that plan. Our clearing firm represents that it will advise us of any material changes to its plan that might affect our ability to maintain our business.

A. Our Firm's Mission Critical Systems

 

1. Order Taking

Currently, our firm receives orders from customers via telephone at 925-457-0275. During an SBD, either internal or external, we will continue to take orders. Customers will be informed of alternatives by email. If necessary, we will advise our customers to place orders directly with our clearing firm Shareholders Service Group at (800) 380-7370.

2. Order Entry

Currently, our firm enters orders by recording them on paper and electronically and sending them to our clearing firm electronically or telephonically. In the event of an internal SBD, we will enter and send records to our clearing firm by telephone. In the event of an external SBD, we will maintain the order in electronic or paper format, and deliver the order to the clearing firm by the fastest means available when it resumes operations. In addition, during an internal SBD, we may need to refer our customers to deal directly with our clearing firm for order entry.

3. Order Execution

Order execution is the responsibility of our clearing firm Shareholders Service Group.

 

B. Mission Critical Systems Provided by Our Clearing Firm

B. Mission Critical Systems Provided by Our Clearing Firm

 

Our firm relies, by contract, on our clearing firm to provide order execution, order comparison, order allocation, customer account maintenance and/or access and delivery of funds and securities.

 

Rules: FINRA Rules 3510(c)(2) & (g)(1).

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IX. Alternate Communications Between the Firm and Customers, Employees, and Regulators

 

A. Customers

We now communicate with our customers using telephone, email, our website and in-person visits. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by email but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.

 

Rule: FINRA Rule 4370(c)(4).

B. Employees

 

This business is run by a sole proprietor.

 

Rule: FINRA Rule 4370(c)(5).

 

C. Regulators

 

We are currently members of the following self-regulatory organizations (SROs), and are also regulated by: California Department of Business Oversight. We communicate with our regulators using telephone, email, and U.S. mail. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.

 

Rule: FINRA Rule 4370(c)(9).

 

Critical

X. Critical Business Constituents, Banks, and Counter-Parties

 

A. Business constituents

 

We have contacted our critical business constituents and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need from them because of a SBD to them or our firm.

 

Rules: FINRA Rule 4370(c)(7).

B. Banks

 

We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of the internal or external SBD. The bank maintaining our operating account is: US Bank | 4663 Clayton Rd, Concord, CA 94521 | 925-676-6750 |. If our banks and other lenders are unable to provide the financing, we will seek alternative financing immediately.

 

Rules: FINRA Rule 4370(c)(7).

 

C. Counter-Parties

 

We have contacted our critical counterparties to determine if we will be able to carry out our transactions with them in light of the internal or external SBD. Where the transactions cannot be completed, we will work with our clearing firm or contact those counterparties directly to make alternative arrangements to complete those transactions as soon as possible.

 

Rules: FINRA Rule 4370(c)(7).

 

XI. Regulatory Reporting

XI. Regulatory Reporting

 

Our firm is subject to regulation by the California Department of Business Oversight. We now file reports with our regulators electronically through email and the Internet. In the event of an SBD, we will check with the SEC, FINRA and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

 

Rule: FINRA Rule 4370(c)(8).

XII. Disclosure of Business Continuity Plan

XII. Disclosure of Business Continuity Plan

 

Attached is our written BCP disclosure statement we provide customers at account opening. We also post the disclosure statement on our website and email it to customers upon request.

 

Rule: FINRA Rule 4370(e).

XIII. Updates and Annual Review

XIII. Updates and Annual Review

 

Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our firm will review this BCP annually, on January 31st, to modify it for any changes in our operations, structure, business or location or those of our clearing firm.

 

Rule: FINRA Rule 4370(b).

XIV. Senior Manager Approval

XIIV. Senior Manager Approval

 

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.

 

Rule: FINRA Rule 4370(d).

 

Signed: /Joseph S. Carrano/

Title: CEO

Date: January 2, 2020

Attachment A

Attachment A to Carrano Financial Planning, LLC

Business Continuity Plan

 

Carrano Financial Planning, LLC Business Continuity Planning

 

Carrano Financial Planning, LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us

 

If after a significant business disruption you cannot contact us as you usually do at 925-57-0275 or info@carranofinancial.com, you should contact our clearing firm, Shareholders Service Group at (800) 380-7370 and https://www.ssginstitutional.com 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.

 

Our Business Continuity Plan

Our Business Continuity Plan

 

We plan to quickly recover and resume business operations

after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

 

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

 

Our clearing firm, Shareholders Service Group, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within three business days. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions

Varying Disruptions

 

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within one business day. In a disruption affecting our business

district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within three business days. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website https://carranofinancial.com how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For More Information

For More Information

 

If you have questions about our business continuity planning, you can contact us at 925-457-0275 or info@carranofinancial.com.