Reviewed June 30, 2016
ICD’s BUSINESS CONTINUITY PLAN DISCLOSURE
Institutional Cash Distributors, LLC (“ICD”) has developed a Business Continuity Plan (BCP) describing how we will respond to events that significantly disrupt our business. Because 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 +1.800.611.4423 and/or info@icdportal.com, you should call our alternate number +1.424.206.2400 in the U.S. or +44(0)207-968-4774 in the UK, e-mail trading-icd@icdportal.com, or visit http://icdportal.com where you can obtain additional information. If you cannot access us through those means, you should contact our clearing firm or custody agent for instructions on how to gain prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.

CLEARING ACCOUNTS
JPMorgan Clearing Corp
383 Madison Ave 
Fl #23
New York, NY 10179 
+1.212.552.1919

CUSTODY ACCOUNTS
Union Bank
350 California, 
6th Floor
San Francisco, CA 94104
Attention – Portal
+1.877.578.7255 Client Service
+1.877.445.3599 Password Re-sets

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 firms 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 back up 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. 

ICD uses disk-to-disk and disk-to-tape backup solutions. These backup solutions provide off-site storage of our internal documents including, but not limited to, data production, e-mail and IM. In addition our clearing firm, JPMCC, backs up their 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 4 to 12 hours. Your orders and requests for funds and securities could be delayed during this period.

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 an alternate location when needed and expect to recover and resume business within the same 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 24 hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.icdportal.com or our customer emergency number, +1.424.206.2400. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.

FOR MORE INFORMATION
The ICD Business Continuity Plan is reviewed periodically and subject to modification without notice. The Business Continuity Plan disclosure is posted on our website at http://icdportal.com. A written copy of the summary of our Business Continuity Plan is provided to customers upon request. If you have questions about our Business Continuity Plan, you can contact us at +1.800.611.4423 and/or info@icdportal.com.