Business Continuity Disclosure Policy
Currently you maintain an account at our firm, Cutter & Company, Inc. Through your financial advisor, our firm provides technology, product, and support services for the account you maintain with us. Your assets are held at one of our two clearing firms, First Clearing, LLC, or RBC Correspondent Services. Alternatively, some client assets are held directly at the mutual fund or annuity company.
Securities Industry regulations require that each member firm create and maintain a “Business Continuity Plan” (BCP), which is reasonably designed to meet our obligations to our clients in the event of a disruption to our business. Accordingly, Cutter & Company has designed a BCP to address a variety of possible scenarios in an effort to minimize any service impact to our clients.
Some of the key areas that are addressed in our BCP include, but are not limited to the following
- Data back-up and recovery
- Operation of mission critical systems
- Financial and operational assessments
- Alternate means of communication between our financial advisors and our clients
- Alternate physical locations
- Regulatory reporting
- Communication with regulators
- How Cutter and Company will ensure customers will have access to their account information and/or funds or securities in the event that Cutter determines it is unable to continue its business.
There are a significant variety of events that may cause business disruptions. These events may vary in nature and scope. Cutter & Company has anticipated the following scenarios:
- A temporary disruption at its main offices in Ballwin, Missouri (less than 24 hours)
- A more lengthy disruption at its main offices in Ballwin, Missouri
- A city wide catastrophe
- A regional catastrophe
In the event of a temporary or lengthy building disruption at the main office of Cutter & Company, all phones will be forwarded to our Clearing Firm utilizing an 800# number or routed to an alternate location, with a local number. Once the disruption is over, all office phones will be switched back to our normal main line phone number. Additionally, our web site will be updated to include emergency contact information for at least two of the principals of Cutter & Company, indicating both their home and cell phone numbers. In the unlikely event of a city wide or regional disruption, Cutter & Company has established a relationship with another local Broker Dealer, approximately 20 miles from our location, where key employees may be relocated until the disruption has ended. Alternatively, our key employees may be relocated to one of our financial advisor’s offices in O’Fallon, Missouri, depending on the nature and location of the emergency. However, if the geographic incident should encompass our alternate locations, than all contact will be directed to our clearing firms. Alternatively, Cutter & Company has a backup arrangement with an unaffiliated broker-dealer partner located in Buffalo, NY. In the event of a geographic disaster that requires us to operate further from our main office location, essential personnel may be dispatched to their New York location.
At a minimum the Cutter & Company BCP is reviewed, updated, and tested on an annual basis. Additionally, our primary mission critical systems and applications are tested periodically each year to verify that all are in working order.
Feel free to call 636-537-8770 if you would like us to mail you a written copy of the Cutter & Company BCP plan.
Order Routing Practices
Cutter & Company uses First Clearing Corp LLC and RBC Correspondent Services as our clearing firm partners. Please click on the respective link below to view the aggregate routing data of each clearing firm. Please don’t hesitate to contact us directly if you would like to request routing data pertaining to a specific customer order. You can reach us at 800-536-8770.
|First Clearing Accounts||RBC Correspondent Services|