Global AutoTrading Inc.
Business Continuity Plan
Revised: February 11, 2024
1. Emergency Contact Person
Global AutoTrading Inc. emergency contact person can be reached at service [at] global-autotrading.com . The contact person will be updated in the event of a material change, and will be reviewed within 10 business days of the end of each quarter.
2. Policy
Global AutoTrading’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 autotrading service to remain operational. In the event that we determine we are unable to continue our autotrading service, we will inform customers to contact their carrying broker (Interactive Brokers, Tradier or AutoShares) to access their funds, manage their positions, and close their account.
2.1 Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only Global AutoTrading’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operations 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 carrying brokers. All our carrying brokers are located in different cities from Global AutoTrading, thus they are unlikely to be affected by a local event.
2.2 Approval and Execution Authority
The president, CEO & CCO of Global AutoTrading Inc. is responsible for approving the plan and for conducting the required annual review, and for executing this BCP.
2.3 Plan Location and Access
Global AutoTrading will maintain copies of its BCP, the annual reviews, and the changes that have been made to it for inspection, at its head office.
3. Business Description
Global AutoTrading conducts business in equity and derivative securities. Our firm is an investment advisor and does not hold client funds or securities. We enter orders in our clients’ accounts which are held with 3rd party brokers.
4. Office Location
The Global AutoTrading head office is located in Toronto, Ontario.
5. Alternative Physical Location(s) of employees
In the event of an SBD, we will attempt to move staff members to an unaffected physical location, the location of which depends on the SBD and will be determined at the time.
6. Customer’s Access to Funds and Securities
Global AutoTrading does not maintain custody of customers’ funds or securities; custody is maintained by our carrying brokers. In the event of an internal or external SBD, if telephone service is available, our registered persons will take instructions and contact our carrying brokers on their behalf. If our internet access is available, Global AutoTrading will post on our Web site how our customers may access their funds and securities (generally, our clients can contact their broker directly).
7. Data Back-up and Recovery
Global AutoTrading maintains its primary hard copy books and records and its electronic records at its head office. The president & CCO is responsible for maintenance of these books and records. The firm backs up its electronic records to an off-site location.
In the event of an internal or external SBD that causes the loss of our paper records, we can recover copies electronically from our off-site location.
8. Financial and Operational Assessments
8.1 Operational Risk
In the event of an SBD, Global AutoTrading will immediately identify what means will permit us to communicate with our customers, employees, and carrying brokers. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our Web site, telephone voice mail, and e-mail. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery.
8.2. 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.
9. Mission Critical Systems
Global AutoTrading’s “mission critical systems” are those that ensure continuation of its autotrading service. More specifically, these systems include internet access, email access, and at least one computer to run Global AutoTrading’ autotrading platform. Our carrying brokers maintain their own business continuity plan which can be accessed on their web site at https://www.interactivebrokers.com/Universal/servlet/Registration_v2.formSampleView?doc=showIBContinuityPlanDisclosure.jsp , https://s3.amazonaws.com/documents.tradierbrokerage.com/hilltop/tradier_brokerage_inc_bcp.pdf , and https://www.autoshares.com/business-continuity-plan as of the time of this writing.
10. Disclosure of Business Continuity Plan
Global AutoTrading posts this document on our Web site and emails it to clients upon request.
11. Updates and Annual Review
Global AutoTrading will update this plan whenever there is a material change to our operations, structure, business, or location or to those of our carrying brokers. In addition, we will review this BCP annually, to modify it for any changes in our operations, structure, business, or location or those of our carrying broker.
12. Disclaimers
Global AutoTrading will adhere to the procedures set forth in its Business Continuity Plan and described in this disclosure to the extent commercially reasonable and practicable under prevailing circumstances. However, there are innumerable potential causes of a business disruption. In addition, disruptions (and the events that caused them) may vary significantly in nature, size, scope, severity, duration and geographic location and will result in distinct degrees of harm to human life; firm assets; the banks, exchanges, clearing houses and depositories with which the firm conducts business; and local, regional and national systems infrastructure (e.g., telecommunications, Internet connectivity, power generation and transportation) that could affect the firm's recovery in vastly disparate ways. In recognition of this, Global AutoTrading reserves the right to flexibly respond to particular emergencies and business disruptions in a situation-specific manner which the firm deems prudent, in its sole discretion. Nothing in this document is intended to provide a guarantee or warranty regarding the actions or performance of Global AutoTrading, its computer systems, or its personnel in the event of a significant disruption. Global AutoTrading may modify its Business Continuity Plan and this disclosure at any time. Global AutoTrading will post updates to its Business Continuity Plan Disclosure on its website.