Monroe Financial Partners, Inc.’s Business Continuity Planning
Monroe Financial Partners, Inc. (“MFP”) has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us – If after a significant business disruption, you cannot contact us as you usually do at 800-766-5560, you should call our alternative number 312-327-2530. If you cannot access us through either of those means, you should contact our clearing firm, National Financial Services, for instructions on how it may accept orders and provide prompt access to funds and securities:
National Financial Services
To contact a representative from NFS: 800-343-3548
Please note, if an emergency exists, accepted orders may be limited to liquidating positions.
Our Business Continuity Plan – We plan 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, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan 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 counterparty impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, National Financial Services, backs up our important records in a geographically separate area. While every emergency poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our 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 four hours of disruption. Your orders and requests for funds and securities could be delayed during this period.
Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to an alternative location and expect to recover and resume business immediately, and in full capacity within one day. In a disruption affecting our business district, city, or region, our strategy will be the same. We will transfer our operations to a backup site and recover and resume business at full capacity as soon as possible. In either situation, we plan to continue in business, and possibly transfer operations to our clearing firm if necessary. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
If you have questions about our business continuity planning, you can contact the Firms Chief Compliance Officer, Kristin Love at (312) 521-1435
Cyber Security Program
Considering the reliance on technology and the internet, Monroe Financial Partners has developed a robust cyber security program that expands upon the business continuity plan. The purpose of the cyber security program is to proactively identify risks & emerging threats, develop appropriate responses, create policies & procedures, conduct periodic testing and implement routine general system monitoring. Minimizing risk by protecting company technology, securing company and customer information, and ensuring systems are not vulnerable to threats are central to the Firm’s Cyber Security Program.
Covid-19 – In the event of another pandemic like the Covid-19 pandemic or another “act of god” event, all features of the firm’s cyber security program will continue to be followed. All users have firm approved terminals with a secure VPN connection to the company’s internal network. All customer and account information are secure, and all systems are monitored routinely in accordance with previously established program processes.
Privacy Policy
We respect the privacy of customer information provided to us. The purpose of this notice is to explain our privacy policy to you both in legal terms and by example. We collect information about you from the data we receive from you on applications and other forms and from your transactions with us. We do not disclose any nonpublic personal information about you to anyone except as required by law and except to transmit information to our clearing agent (see explanation infra). If you decide to close your account or become an inactive customer, we continue to adhere to the privacy policies and practices as described in this notice. We restrict access to your personal account information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. An example of a situation where we would be required by law to disclose nonpublic personal information about you —We receive a subpoena from a governmental agency to provide information about you. If we are required by law to provide the information, we must do so. We do not carry any customer accounts. All our customer assets are held by National Financial Services. Even though we do not carry customer accounts, you are considered to be a customer of ours. That is why we are sending you this notice. To enable National Financial Services to clear transactions we make with you, we transmit nonpublic personal information to them that you have provided to us along with the details of any transaction you have made. You are also considered to be a customer of National Financial Services. They also have an obligation to you concerning your privacy. It is their obligation to communicate to you directly concerning their privacy policy.
Securities and Exchange Commission Rule 606: Best Execution
On any orders you place with our firm, we are obligated to obtain for you the best execution we possibly can. We may execute your order as agent or principal. In either case, we will obtain for you the best execution possible. We want you to know in general, we do not route orders as we execute them from our book. In the unlikely event we route your order we are obligated to no other firm to favor them with orders. We go where we feel the best execution can be obtained. We do not receive payment from other firms for order flow and we are free to execute orders wherever we want to. If at any time, you desire to know how a particular order that you gave to us was routed, please contact us and we will provide you with that information.
Securities and Exchange Commission Rule 607: Payment for Order Flow
Pursuant to NMS [Rule 607 (a)(1)-(2)] requires that all broker/dealers acting as agent notify their customers of their payment for order flow practices at account opening and on an annual basis. All registered brokerdealer firms, including those firms which do not participate in payment for order flow practices, must make an annual disclosure to their customers. Monroe Financial Partners, Inc. does not participate in payment for order flow practices. Monroe does not receive any payments for order flow and does not make payments to any party for order flow.
FINRA Information
Pursuant to Financial Industry Regulatory Authority (“FINRA”) Rule 2267, please be advised of the following:
1. As part of its Public Disclosure Program, FINRA offers the following toll-free telephone listing 1-800-289- 9999, which affords you the opportunity to check for any disciplinary history of its members (brokerage firms which belong to FINRA) and their associated persons (stockbrokers, traders and any registered persons employed by FINRA members). Information can also be found on the FINRA website (www.FINRA.org) and the broker check website www.brokercheck.FINRA.org
2. FINRA maintains the following website, www.FINRA.org. The website provides a wealth of information including recent developments such as rule changes and press releases, how to resolve disputes and disclosure of recent disciplinary matters.
3. An investor brochure is available that includes information describing the FINRA’s Public Disclosure Program. Availability of the brochure will be made through either the “800” toll free number or the FINRA website mentioned above.
SIPC Information
Pursuant to SEC Rule 2342, as a Securities Investor Protection Corporation member (“SIPC”), MFP is required to notify customers that they may obtain information about SIPC, including the SIPC brochure, by contacting SIPC. To contact SIPC or obtain more information please visit ww.sipc.org or call 202-371-8300.
Complaint Department
Pursuant to paragraph (ii) of SEC Rule 17a-3(a)(18), Monroe Financial Partners, Inc. is required to provide its customers with the address and telephone number of the department of the firm to which any complaints may be directed.
Complaints can be directed to:
Monroe Financial Partners, Inc.
500 W Madison, Suite 450
Chicago, IL 60661
Attn: Kristin Love
Tel: (312) 521-1435