Business Continuity Plan
International Assets Advisory, LLC (“IAA”), in conjunction with its affiliates, maintains a Business Continuity Plan (the Plan) that covers the resumption of business processes for each IAA department in the event of a business interruption, consistent with applicable regulations, including FINRA Rule 3510. These plans are updated whenever there is a material change to the IAA business.
IAA is providing you with this document to inform you of its ability to respond to certain business disruptions at your Financial Advisor’s local office or at the main office of IAA. Your Financial Advisor is associated with IAA and, as a result, all transactions that you place through him or her are processed through IAA’s systems. IAA’s ability to respond to business disruptions is therefore important to your relationship with your Advisor.
In general, IAA maintains a Business Continuity Plan and intends to continue business in the event of a significant business disruption. IAA is an introducing broker/dealer and, as such, it relies on its correspondent-clearing firm to perform certain functions on its behalf, including the execution of securities transactions and the maintenance of customer funds and securities. Accordingly, the Firm’s ability to respond to certain business disruptions is partially dependent on our clearing firm.
In the event of a significant business disruption at either the local or main office, IAA may route calls to an office location in a separate geographic location and, if necessary, transfer operations to a facility maintained by a third party vendor. Although IAA intends to continue business in the event of a significant business disruption, there are some disruptions that may render the Firm or your Financial Advisor unable to continue business. Under such circumstances, IAA will ensure that clients will be able to access their funds and securities within a reasonable time.
To provide clients with up-to-date information during a significant business disruption to your Financial Advisor’s local office or the main office of IAA, clients may call the Firm’s toll free telephone number at (844) 567-4544 or visit our emergency information Web page at www.IAAC.com. Additionally, IAA policy requires formal semi-annual reviews, including business risk assessments of the Plan. Changes to IAA processes, products, or the business environment are evaluated, and modifications to the configuration of IAA Business Continuity Disaster Recovery Sites (Recovery Sites) are performed as required. Current copies of the Plan are maintained in an off-site location.
IAA also maintains Recovery Sites for its personnel. The Recovery Sites provide for the relocation of IAA associates to resume processing operations and trading functions in the event of a business interruption. Each operations or trading workstation to be used under the Plan is equipped with all the software, as well as all the telecommunication equipment, needed for IAA associates to continue in their role. A centralized fax and wire printer room, where all communications to IAA are controlled, is also maintained.
IAA’s Response to Events of Varying Scope
The following sections describe specific events and IAA’s corresponding general response to those events. Clients, however, should note that these responses are subject to modification and, depending on the severity of a specific event, IAA cannot guarantee that it will be able to follow the stated course of action. If these responses are modified, IAA will post the updated disclosure statement on its Web site. In the alternative, you may request from your Financial Advisor that the Firm send you, by mail, a copy of the updated disclosure statement.
Under the following scenarios, IAA intends to continue its business:
A Disruption to a Single Building or Firm-Only Business Disruption
These disruptions may be caused by physical damage, technology problems, or an inability to have personnel arrive at an office. In the event that there is a significant business disruption to a single building or the Firm’s internal primary systems, IAA may, if necessary, transfer its operations or route incoming calls to another office in a separate geographic location. From this separate location, IAA will accept client orders. In this process, clients may experience a minor delay in reaching the firm due to increased client calls, technology delays, or other minor difficulties arising from the transfer of operations. IAA expects that operations could be disrupted for up to one (1) hour. If IAA’s trading platform is affected, there may be a more significant delay. IAA, however, will be able to place orders outside the trading platform.
A Business-District, City-Wide, or Regional Disruption
In the event that there is a significant business disruption that affects the business district, city, or region where any of the Firm’s primary systems are located, IAA may, if necessary, transfer its operations or route incoming calls to another office in a separate geographic location office. In this process, clients may experience a minor delay in reaching the firm due to increased client calls, technology delays, or other minor difficulties arising from the transfer of operations. If the disruption is significant, IAA may transfer its operations to a third-party
service provider. In addition, if our clearing firm in affected by the business-district, citywide, or regional disruption, clients may experience additional delays. Nevertheless, IAA expects that operations could be disrupted for up to four (4) hours.
In the event you are unable to contact your investment advisor due to a significant business interruption, IAA may be contacted directly by you to process limited trade-related transactions, cash disbursements, and security transfers. Such instructions to IAA must be in writing and transmitted via facsimile or postal service as follows:
International Assets Advisory LLC
390 North Orange Avenue, Suite 750
Orlando, Florida 32801
Fax: (407) 254-1505
For additional instructions, please select the Business Continuity and Customer Support links at the bottom of the home page on the IAA web site at http://www.IAAC.com, or contact IAA at (844) 567-4544.
DISCLOSURE REQUIRED BY NEW YORK STOCK EXCHANGE® RULE 409A AND FINRA RULE 2342
Information regarding the Securities Investor Protection Corporation (SIPC®), including a SIPC brochure, may be obtained by contacting SIPC via its web site at http://www.sipc.org/ or by telephone at (202) 371-8300.
The following describes how International Assets Advisory, LLC (“IAA”) handles your personal information and what steps we take to protect your privacy:
IAA is concerned about your privacy. As an integral part of providing quality financial products and services to you, we collect certain personal information about you. We do not sell this personal information to third parties, and we disclose this information only as absolutely necessary to provide the products and services you have come to expect from us. This Privacy Notice is provided solely for your information and it is not necessary for you to take any action. Nevertheless, you have certain rights as described below.
In order for our operating subsidiaries to conduct business, they collect nonpublic personal information about you from:
* applications or other necessary forms, such as your name, address, social security number, assets, liabilities and income, employment status and dependent information;
* your transactions with our operating subsidiaries, affiliates or others, such as your account activity and products and services purchased; and
* visitors to our websites, such as information from online forms, site visitorship data and online information collecting devices.
Within our organization, we restrict access to nonpublic personal information about you to those employees who must know such information in order to provide you with the quality financial products and services you deserve. We maintain safeguards that comply with federal and state regulations and protect your nonpublic personal information. We may also disclose all of the information described above to non-affiliated third parties with whom we, or any of our operating subsidiaries, contract for services such as: third party administrators, investment companies, insurance companies, investment advisers, companies that perform marketing services on our behalf or other institutions with whom we have joint marketing agreements. We contractually require that these third parties maintain physical, electronic, and procedural safeguards that comply with federal and state standards to safeguard your nonpublic personal information. Nevertheless, we may disclose your nonpublic personal information to self- regulatory authorities and other regulatory authorities, law enforcement or other governmental authorities as reasonably necessary to conduct our business or as otherwise permitted or required by law.
Our privacy policies will continue to apply even after you cease to have any customer relationship with us or with any of our operating subsidiaries.
We do not disclose your nonpublic personal information to third parties except as necessary to provide our products and services to you.
Opting out of Third Party Disclosures And Other Rights: If you prefer that IAA or its representatives do not disclose the nonpublic personal information about you to nonaffiliated third parties, you may opt-out of those disclosures, that is, you may direct us to not make those disclosures (other than disclosures permitted by law). If you wish to opt-out of disclosures to nonaffiliated third parties, or you notice an error in your personal information, you may contact our Compliance Department at 407-254-1500 or send a written request to IAA, Attn: Compliance Department, 390 N. Orange Ave, Suite #750, Orlando, FL 32801.
For California Residents under the California Consumer Privacy Act (CCPA): To submit a request to access your personal information we hold on you or to submit a deletion request for certain personal information, please contact IAA’s Compliance Department.