Intercoastal Capital Markets, Inc. Business Continuity Plan

Purpose of the Business Continuity Plan

The Business Recovery Plan at Intercoastal Capital Markets, Inc. (Firm) is intended to provide a framework to ensure the Firm’s uninterrupted operations and/or restoration of its business and operations in the most efficient and timely manner in case of an internal or external SBD (Significant Business Disruption). An SBD can be caused by any accidental, natural or man-made malicious event that threatens or does disrupt normal operations or services for a sufficient time to affect significantly, or cause failure to, an organization.

I. Emergency Contact Persons

Our Firm’s three (3) emergency contacts are:

John W. Rogers Jr.
General Principal, Chief Operations Officer & Chief Compliance Officer
Phone – 561-939-8258
Cell – 561-459-7254
Email: jrogers@intercoastalcm.com

Karen Z. Fischer
General Principal, Chief Financial Officer and Fin-Op
Phone – 561-939-8282
Cell – 561-789-7403
Email: kfischer@intercoastalcm.com

C. David Bird
General Principal and Chief Executive Officer
Phone – 561-939-8282
Cell – 954-242-1947
Email: db@intercoastalcm.com

These names and information will be updated in the event of a material change, and will be reviewed within 30 business days of the end of each fiscal year.

II. 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 clients to transact business. In the event that we determine that we are unable to continue our business, we will assure clients prompt access to their funds and securities.

Significant Business Disruptions (SBDs)

Our plan anticipates two kinds of SBDs. Internal SBDs are interruptions that deny access to our facilities or resources and only affect our Firm’s ability to communicate and conduct business. External SBDs prevent the operation of the securities markets or a number of firms. With either type of disruption, if our critical Information Technology systems are disrupted, we will have to rely on our key third party processors, vendors, suppliers and financial institutions. Whether the disruption is internal or external, Intercoastal Capital Market’s plan is designed to recover our business functionality and process all outstanding business.

Rule: FINRA Rule 4370(e)

Plan Location and Access

We maintain a copy of this BCP at our external backup facility (see VII Data-Backup and Recovery.) Copies of the BCP have been distributed among department heads.

Approval and Execution Authority

John Rogers, registered principal, is responsible for approving the plan for Intercoastal Capital Markets, Inc. and for conducting the required annual review. Mr. Rogers can be reached at 716-332-6129 or jrogers@intercoastalcm.com.

Rule: FINRA Rule 4370(d)

III. Business Description

Intercoastal Capital Markets, Inc. is a FINRA registered broker/dealer, servicing both retail and institutional customers with the ability to transact business in Corporate Equity, Corporate Debt, Mutual Funds, Options, US Government and its Agencies fixed income securities, Municipal Bonds, Insurance & Annuities offerings and Private Placements. Our firm is an introducing firm. We do not hold customer funds or securities. Our clearing firm maintains customers’ accounts and transactions.

Our clearing firms are INTL FCStone formerly Sterne, Agee & Leach, Inc. (member NYSE/FINRA/SIPC) and Hilltop Securities Inc. (member NYSE/FINRA/SIPC.) INTL FCStone has multiple locations, and may be contacted as follows:

INTL FCStone formerly INTL FCStone Florida Branch Offices
2600 N Military Trail Ste. 290
Boca Raton, Florida 33431
800-264-4863
www.sterneagee.com

INTL FCStone Corporate Headquarters
800 Shades Creek Parkway, Suite 700
Birmingham, Alabama 35209
205-949-3500/800-240-1438
Operations – 888.678.3763
https://www.intlfcstone.com

Hilltop Securities may be contacted at:

Hilltop Securities Inc.
1201 Elm Street
Ste. 3500
Dallas, TX 75270
214-859-1800/800-973-7977
Operations – 214-859-5275
www.swst.com

IV. Office Location and Contact Information

Intercoastal Capital Markets Inc. has 3 branch office locations.

Intercoastal’s main OSJ world headquarters are located at:

5550 Glades Road, Suite 308, Boca Raton, FL 33431. The main telephone number is (561) 939-8282. The fax number is 626-219-8525. Our web site address is www.intercoastalcap.com. Our contact email is jrogers@intercoastalcm.com. The Firm’s office location in Boca Raton is maintained and managed by:

Town Center Executive Suites
Boca Financial Plaza
5550 Glades Road
5th Floor
Boca Raton, FL 33431
Direct Contact: Annette Reizburg
Tel: (561) 961-5400
Email: areizburg@comcast.net
Web Site: www.towncenterexecutivesuites.com

Intercoastal’s OSJ branch office in New Jersey is located at:

426 Springfield Avenue, 2nd Floor, Summit, NJ 07901. The main telephone number is (908) 200-2311. The fax number is 908-200-2312. The web site address is the same at www.intercoastalcap.com. The contact email is the same at jrogers@intercoastalcm.com. The Firm’s office location in Summit is maintained and managed by:

Spes. Summit LLC
426 Springfield Avenue, 1st Floor
Summit, NJ 07901
Direct Contact: Annette Dwyer
Tel: (917) 969-4534
Email: annettemfdwyer@gmail.com

Intercoastal’s OSJ branch office in New York is located at:

1207 Delaware Avenue, Ste. 118, Buffalo, NY 14225. The main telephone number is (716) 332-6129. The web site address is the same at www.intercoastalcap.com. The contact email is the same at jrogers@intercoastalcm.com. The Firm’s office location in Amherst is maintained and managed by:

Plaza Group Suites
One Towne Center, 501 John James Audubon Parkway
Amherst, NY 14228
Direct Contact: John McDonald
Tel: (716) 874-4880
Email: johnmcdonald@plazagroup.com

V. Alternative Physical Location(s) of Employees

In the event of an SBD, we will continue operations at an alternate working location. Additionally, the Firm has provided some employees with computers preconfigured with access to mission critical applications.

The Firm will first have alternate branch office locations serve as an alternate location for any SBD affected branch.

The Firm also maintains an alternate working location at the following principal’s/persons in charge personal residences:

David Bird
177 Royal Palm Way
Boca Raton, FL 33432
(954) 242-1947

John Rogers
92 Yeager Drive
Buffalo, NY 14225
(561) 459-7254

Vincent G. McCallion
110 Second Street
Fanwood, NJ 07023-1629

Additionally, if these alternate locations are not available, the Firm will relocate its’ operations and mission critical systems to one of its’ clearing agents – INTL FCStone or Hilltop Securities Inc.’s locations (see III. Business Description) that is accessible and/or operational.

Rule: FINRA Rule 4370(c)(6)

VI. Customers’ Access to Funds and Securities

Our Firm does not maintain custody of customers’ funds or securities. In the event of an internal or external SBD, our registered employees will take customer orders or instructions over any available method and our customers may execute any kind of transaction by contacting the Firm via our main phone number, cell phone numbers under emergency contacts or, if necessary, by calling our clearing firm directly.

Rule: FINRA Rule 4370(c)(10)

VII. Data Back-Up and Recovery

The Firm has contracted with independent vendors to host and backup all electronic mail and electronic files off-site to external storage facilities on a daily basis. The firm has also contracted with independent vendors to archive other non-electronic firm documentation (such as employee records, administrative contracts and system generated reports for reconciliation, etc.) off-site to external storage facilities on an as needed and allowed basis. The firm maintains access to those records and files at any given time, so in the event of an internal or external SBD we can always recover the Firm’s records.

The Firm’s email is hosted and electronically archived with:

Smarsh, Inc.
921 SW Washington Street Suite 540
Portland, OR 97205
Phone: 866-SMARSH-1 (866-762-7741)
Email: support@smarsh.com
Web Site: www.smarsh.com
Direct Contact: Geoff Dilkes, Account Executive; 971-270-1179; gdilkes@smarsh.com

The Firm’s files are physically and electronically archived and redundantly backed up locally and remotely. This includes local limited access server, portable drive and Google Drive.

Rule: FINRA Rule 4370(c)(1)

VIII. Financial and Operational Assessments

A. Operational Risk
In the event of an SBD, we will immediately identify and use any methods that permit us to communicate with our customers, employees, business, constituents, banks and regulators.

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.

Rule: FINRA Rule 4370(c)(3)

IX. Mission Critical Systems

Our Firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions and the maintenance of customer accounts. We have primary responsibility for maintaining our relationships with customers. Our clearing firms, Sterne, Agee & Leach, Inc. and Southwest Securities Inc., provide the execution, comparison, allocation, clearance and settlement of securities transactions and the maintenance of customer accounts. Our clearing firms’ contracts require our clearing firms to maintain a business continuity plan and the capacity to execute it. Our clearing firms represent that it backs up all of their pertinent records.

Rule: FINRA Rule 4370(c)(2))

X. Communications between the Firm, Customers, Employees, and Regulators

In the event of an SBD, we will use the means comparable in speed and form to the means that we have used in the past to communicate with our customers, employees and regulators. We will always keep all parties informed with status reports on the situation of the business.

Rule: FINRA Rule 4370(c)(4)(5)(9)

XI. Critical Business Constituents and Banks

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 the event of an internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services.

The Firm is contracted with the following primary critical business constituents:

INTL FCStone for clearing and operations services (see III. Business Description for contact information.)

Hilltop Securities Inc. for clearing and operations services (see III. Business Description for contact information.)

Town Center Executive Suites for office management/landlord (see IV. Office Location and Contact Information.)

Spes. Summit, LLC for office management/landlord (see IV. Office Location and Contact Information.)

Plaza Group Suites for office management/landlord (see IV. Office Location and Contact Information.)

Bloomberg L.P. for market and trading systems. Their contact information is:

Bloomberg L.P.
731 Lexington Ave.

New York, NY 10022
U.S. East Coast Customer Support Phone: 212-318-2000
Email: via Bloomberg system or form on web site
Web Site: www.bloomberg.com

B. Banks

We have contacted our banks and lenders to ensure they maintain their own Business Continuity Plan and have the capacity to deploy it in the event of an internal or external SBD.
The Firm is contracted with the following bank for monetary business transactions:

Wells Fargo Bank
5355 Town Center Road Suite 101
Boca Raton, FL 33486
Phone: 561-338-6021/561-417-3183
Fax: 561-338-6808
Web Site: www.wellsfargo.com
Email: via a form on Contact Us page on web site

Rule: FINRA Rule 4370(c)(7)

XII. Regulatory Reporting

Our Firm is subject to regulation by the Financial Regulatory Authority (FINRA) and the U.S. Securities & Exchange Commission (SEC.) In the event of an SBD, we will verify with these authorities the means of filing still available to us.

The Firm is under the jurisdiction of FINRA District 7 in Boca Raton, Florida. FINRA’s contact information for District 7 is:

FINRA District 7 Office
5200 Town Center Circle
Suite 200
Boca Raton, FL 33486
(561) 443-8000
Fax: (561) 443-7995
Web Site: www.finra.org
Yvette Panetta, Deputy District Director
Tom Nelli, Senior Vice President and Regional Director

The Firm is under the jurisdiction of the SEC and the Division of Trading and Markets & Broker Dealers. The SEC’s contact information is:

SEC Division of Trading and Markets
Washington, D.C.
202-551-5777
Web Site: www.sec.gov
Email: tradingandmarkets@sec.gov

Rule: FINRA Rule 4370(c)(8)

XIII. Disclosure of Business Continuity Plan

We include a copy of this summary to customers in the Firm’s account opening documentation package. We also have posted this summary on our website (www.intercoastalcap.com .) The summary is mailed to customers upon request. In the event of a disruption all customers should refer to this Business Continuity Plan document and/or our website for instructions and direction.

Rule: FINRA Rule 4370(e)

XIV. Updates and Annual Review

Our Firm will update the Business Continuity Plan whenever there is a material change to our operations, structure, business or location or those of our clearing firm. In addition, our Firm will review this BCP periodically for any changes.

Rule: FINRA Rule 4370(b)

XV. SIPC

Should the firm be unable to recover from a disaster, the Firm will follow SIPC liquidation procedures.

For any questions regarding this Business Continuance Plan, please contact the Firm’s compliance department at (561) 939-8282.

Original: 8/20/2012
Updated:1/4/2013- New FinOp and update ICM direct telephone numbers.
Updated: 2/1/2014 – New contacts, additional vendors and general review update
Updated: 4/15/2015 – New contacts, additional information and general review update
Updated: 4/30/2016 – Contact information, clearing firm and regulatory updates and general review update
Updated: 1/4/2017 – Contact information, branch office, clearing firm, regulatory and general review update
Updated: 5/1/2017 – Alternate physical location
Updated: 5/25/2018 – Names, Locations, Personnel Updates