This policy is effective as of October 1, 2016
I. Emergency Contact Persons
Our firm’s two emergency contact persons are:
a. Daniel E. Nagy, 310-850-3868, dan@apexuscapital.com, President & Chief Compliance Officer
a. Apexus Capital LLC, 321 19th Street, Santa Monica, CA 90402
b. Steven
L. Thornton, 626-356-0020, steve@thorntonandassociates.com, FINOP
a. Thornton & Associates, 3542 E Foothill Blvd., Suite 800, Pasadena, CA 91107
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 customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities
A. Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire or power outage in our building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, an earthquake, 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 clearing firm.
B. Approval and Execution Authority
Daniel E Nagy, President & CCO, a registered principal, is responsible for approving the plan and for conducting the required annual review. Daniel E Nagy, President & CCO, has
the authority to execute this BCP.
A. Plan Location and Access
Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on “Apexus Capital LLC” server in the “Business
Continuity Plan” folder containing the file “Apexus Capital LLC BCP 2017”.
