Reviewed November 15, 2023
This policy documents the Firm’s plans with respect to Disaster Recovery, aka Business Continuity (“DR/BC”) with the primary goal of minimizing client service disruptions for the operating businesses of ICD Holdings, LLC (collectively “ICD” or the “Firm”), which include the following:
- Institutional Cash Distributors, LLC
- Institutional Cash Distributors Limited
- ICD Europa – Empresa de Investimento, S.A.
- Institutional Cash Distributors Technologies, LLC
The Firm’s plans will enable the Firm 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 Firm’s books and records, and allowing our customers to transact business. In short, the DR/BC Policy is designed to permit the Firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. The DR/BC Policy addresses: data backup 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’s technical service functions and recovery can be managed without dependency on ICD offices. ICD uses commercially reasonable efforts to make ICD’s technical services available to clients 24 hours a day, 7 days a week, except for scheduled downtime and uncommon exceptions: internet or cloud service provider failure or delay, denial of service attack, DNS failure, or other circumstances beyond ICD reasonable control, including, but not limited to, fire, flood, or other climate events. ICD’s technical services are architected for high availability, with full redundancy. All application data replicates bit by bit every second to a Disaster Recovery site for resiliency.
ICD PERSONNEL – GLOBAL DESK SERVICES
The ICD Global Desk is comprised of four office locations: London, UK; Lisbon, PT; Boston, MA (Cohasset, MA), and San Francisco Bay Area, CA. Multiple office personnel locations allow for personnel redundancies in the event any single office location is rendered inoperable. Global Desk personnel will regularly, and no less than annually, review emergency personal contact details so personnel may be called into support action during local non-business hours. Additionally, at least annually the Global Desk will conduct a real-time office redundancy test to affirm action steps are appropriate for minimal client service disruption. Details of Global Desk DR/BC plans can be found in numerous internal plan documents, including but not limited to call-contact tree and emergency details.
If after a significant business disruption ICD cannot be contacted as usual at +1.800.611.4423 and/or firstname.lastname@example.org, you should call ICD’s alternate number +1.781.374.5152 in the U.S. or +44(0)207-968-4774 in the UK, e-mail email@example.com, or visit http://icdportal.com where you can obtain additional information. If ICD cannot be accessed through those means, clients should contact our clearing firm, custody agent, or direct-investment channel for instructions on how to gain prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.
JP Morgan Services (JPMS)
JPMS, 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, ICD has been advised by its 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. Orders and requests for funds and securities could be delayed during this period.
In the event ICD is not available, clearing clients may contact JPMS at:
JP Morgan Services 383 Madison Ave Fl #23New York, NY 10179 +1.212.622.3076 (or Tickets@jpmchase.com)
MUFG-Union Bank (“MUFG-UB”)
In the event ICD is not available, custody clients may contact MUFG-UB at:
MUFG – Union Bank 350 California, 6th Floor San Francisco, CA 94104 Attention – Portal +1.877.578.7255 Client Service
In the event ICD is not available, Direct-investment clients should contact their investment funds’ Transfer Agent service groups, in accordance with the funds’ prospectus or offering documents.
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 https://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 firstname.lastname@example.org.