Business Continuity Plan Disclosure for Hapoalim Securities USA, Inc.

New York Stock Exchange, Inc. Rule 446 and National Association of Securities Dealers, Inc. Rule 3510 require member firms to create and maintain a business continuity plan (“BCP”).  In accordance with these rules, Hapoalim has developed a plan to help ensure that the Firm can continue to conduct business during an SBD.  Hapoalims’s BCP contemplates disaster scenarios of varying severity including disruption that affects the building, the local business district, a citywide disruption and a regional disruption.  Hapoalim intends to continue to do business during any of these scenarios, but this is subject to the scope and severity of the disruption.  Hapoalim anticipates that the recovery of its mission critical systems and a resumption of business is expected to be within 4 to 6 hours after the disruption for any of the scenarios considered.  Hapoalims’s BCP also addresses customers’ access to funds and securities, data back-up and recovery, mission critical systems, communications between the Firm and customers, employees and regulators, relationships with business constituents and counter-parties and operational, financial and credit risks associated with an SBD.

Hapoalim maintains a disaster recovery facility in a geographical location outside of New York, New York.  The remote location is capable of supporting most of the Firm’s business operations including sales, trading, operations, accounting and information technology.  In the event of a disaster in which the Firm’s management decides that business cannot resume in its current location, key personnel may be relocated to the Firm’s back-up site.  Workstations, phones, printers, fax machines and all other business tools are maintained at the off-site location.  The Firm’s disaster recovery plan is tested annually and key personnel are trained on the business resumption procedures.  

Hapoalims’s BCP is intended to assist in the restoration and resumption of its current business obligations in the event of a disaster.  Regardless of the effort the Firm has placed in the development of its BCP, we appreciate the unpredictable nature of SBDs and understand that there must be flexibility in the implementation of the plan.  Accordingly, the Firm’s BCP is subject to changes and modifications.  Hapoalim intends to update and change its BCP as business conditions and technology change.  Customers may obtain updated plans by requesting a written copy of the plan by mail.