South Street Securities LLC
Business Continuity Plan (BCP)

I. Emergency Contact Persons
South Street Securities LLC (“South Street”), located at 32 Old Slip, 11th Floor, New York, NY 10005, has contracted with Matrix Applications LLC (“MatrixApps”) to provide certain technology and business continuity services, including emergency coordination, during a crisis.
Emergency Management Team:  declares a disaster and sets the direction for the recovery effort.
Disaster Recovery Coordinators:  coordinate the firm-wide mandate of the EMT.
Business Recovery Coordinators:  coordinate the technical and business recovery efforts for their Department.
Staff:  follow the directions of the personnel above, and in this manual.
Below is the emergency contact information for the Business Recovery Coordinators (“BRC”), the Disaster Recovery Coordinators (“DRC”) and the Emergency Management Team (“EMT”).  Personal contact information for all other employees is printed out and stored at the homes of the EMT members.  All contact information is also located at the data centers which can be accessed remotely.

BRC – David DeBlase (SSS)
Home: (516) 594-0417
Office: (212) 824-0738
Mobile: (516) 312-5637
Home Address:
2915 Cleveland Ave
Oceanside, NY 11572
d_deblase@hotmail.com

DRC – Stephen Mellert (Matrix)
Home: (212) 352-0608
Office: (212) 803-5050
Mobile: (646) 498-8748
Home Address:
97 Fifth Avenue, 5B
New York, NY 10003
stephen@melcorp.com

EMT – Stephanie Pucci (SSS)
Home: (718) 459-1041
Office: (212) 824-0738
Mobile: (917) 608-5625
Home Address:
89-27 Metropolitan Ave
Rego Park NY 11374
spucci27@hotmail.com

We update these contacts in the event of a material change and our Chief Compliance Officer reviews them within 17 business days of the end of each quarter.
Rule: NASD Rule 3520.
II. Firm Policy
Our 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 to South Street to transact business.  South Street does not maintain customer accounts and therefore will not retain customer funds and securities.  In the event that we change our business to accept and hold customer funds and securities and we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.
A. Significant Business Disruptions
Our plan anticipates two kinds of SBDs, internal and external.  Internal SBDs affect only our ability to communicate and do business, such as a fire 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, or a wide-scale, regional disruption.  In our response to an external SBD we may rely more heavily on other organizations and systems.
B. Approval and Execution Authority
David DeBlase, Vice President and registered principal, is responsible for approving the plan and for conducting the required annual review.  David DeBlase has the authority to execute this BCP.
C. Plan Location and Access
Our firm will maintain copies of its BCP, annual reviews, and the changes that have been made to the BCP for inspection.  An electronic copy of our plan is located on South Street’s file servers in all three data centers,  in the Disaster Recovery folder.
III. Business Description
Our firm conducts business in the Highly Rated fixed income securities and interest rate futures markets.  We act solely as a Dealer and perform a clearing functions Furthermore, we do not hold customer funds or securities.  We do not engage in any private placements.
IV. Office Locations
Our office is located at 32 Old Slip, 11th Floor, New York, NY 10005.  The main telephone number is 212-803-5050.  Our employees may travel to that office by means of car, bus, or train.
V. Alternative Physical Location(s) of Employees
In the event of a SBD, we will move our staff from our primary to our alternate office location Located at 700 Plaza Drive, Secaucus, NJ 07094  Its main telephone numbers are 201 319-0494.
Rule: NASD Rule 3510(c)(6).
VI. Customer Access to Funds and Securities
South Street acts solely as dealer, does not maintain customer accounts, and therefore does not maintain custody of customer funds or securities.
If South Street changes its business to accept or hold customer funds or securities and SIPC determines that we are unable to meet our obligations to our customers, or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers.  We will assist SIPC and the trustee by providing our books and records identifying customer accounts subject to SIPC regulation.
Rules: NASD Rule 3510(a); Securities Exchange Act Rule 15c3-1; 15 U.S.C. 78eee (2003).
VII. Data Back-Up and Recovery
Our firm has contracted with MatrixApps to backup its electronic books and records.  MatrixApps’s primary data center is located at AT&T’s IDC facility at 811 Tenth Avenue, 16th Floor, New York, NY 10019 (contact Dave Rechen at 212-903-6118).  All equipment and communication lines are fully redundant.  MatrixApps’s disaster recovery data center is located at 4513 Western Avenue, 1st Floor, Lisle, IL 60532 (contact Pam Rockey at 630-810-6218).  The primary MatrixApps contact is Stephen Mellert, Chief Operating Officer (646-498-8748). MatrixApps tests failover and recovery several times a year.
Business related files are located on site at 32 Old Slip, 11th Floor, in a secure local data center.  All files are also replicated to the primary and disaster recovery data centers, in real time.  Data is also backed up incrementally at night to disks located in two off site locations.  Full backups are done weekly and monthly.
SSS uses the Smarsh Email Comply system that helps broker/dealers demonstrate compliance with SEC Rule 17a-4 regarding storage and management of email.  It handles all of the processes involved in collecting, indexing, and archiving email to a fully compliant facility operated within the Smarsh data centers.  Emails are stored for three years, on optical media located at two different physical Smarsh data centers.
In the event of an internal or external SBD that causes a loss of electronic records, we will either electronically recover data from our back-up site or physically recover the storage media.  If our primary site is inoperable, we will continue operations from our an alternate location.
Rule: NASD Rule 3510(c)(1).
VIII. Financial and Operational Assessments
A. Operational Risk
In the event of an SBD, we will immediately identify what means will permit us to communicate most effectively with our employees, critical business constituents, critical banks, critical counter-parties, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include www.southstreetsecurities.com, 212-824-0738, david.deblase@southstreetsecurities.com.  In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Electronic).
Rules: NASD Rules 3510(c)(3) & (f)(2).
B. Financial and Credit Risk
In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. We will contact our critical banks and our investors to apprise them of our financial status. If we determine that we may be unable to meet our obligations to those counter-parties or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations.
If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps.
Rules: NASD Rules 3510(c)(3), (c)(8) & (f)(2).
IX. Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions.
TradeBlazer®- Trading System
Functions:
• Trade entry
• Interface with Clearinghouse
• Interface with Securities and Funds Clearance
• Sub-ledger with interface to general ledger
• Archive reporting
MAS 500 General Ledger
Functions:
• Financial reporting
• Accounts payable
• Archive reporting
• Interface with sub-ledger
BNY GSCX System:
Functions:
• Delivery of securities and cash through Federal Reserve Fedwire system
Communication Systems:
• Exchange Server emails
• Phones
A. Our Firm’s Mission Critical Systems
1. Trade Execution
During an SBD, either internal or external, we will continue to trade through any methods that are available and reliable, and in addition, as communications permit, we will inform our counterparties when communications become available what alternatives they have to communicate with us.
2. Trade Entry
In the event of an internal SBD, we will enter trades into the trading system by the fastest alternative means available.  In the event of an external SBD, we will maintain the trade in electronic or paper format, and enter it by the fastest means available when it resumes operations.
3. Trade Clearance
In the event of an internal SBD, we will clear securities and cash by the fastest alternative means available.  In the event of an external SBD, we will maintain the clearance information in electronic or paper format, and enter it by the fastest means available when it resumes operations.
X. Alternate Communications Between the Firm and Its Counterparties, Employees, and Regulators
A. Counterparties
We now communicate with our counterparties using the telephone, e-mail, our web site, fax, U.S. mail, and in-person visits at our firm or at the their locations.  In the event of an SBD, we will assess which means of communication are still available to us and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.  For example, if we have communicated with a party by e-mail but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.
Rule: NASD Rule 3510(c)(7).
B. Employees
We now communicate with our employees using the telephone, e-mail, and in person.  In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.  We will also employ a call tree so that senior management can reach all employees quickly during an SBD.  The call tree includes all staff home and office phone numbers.  We have identified persons, noted below, who live near each other and may reach each other in person:
The person to invoke use of the call tree is: David DeBlase.
Caller    Call Recipients
David DeBlase    Stephanie Pucci
Home 718 459 1041
Cell   917 608 5625
Monica Urena
Home 212 795 9233
Cell   201 600 9107
Jose Vega
Home 203 454 7796
Cell   203 521 1365
Richard Andrew
Home 718 897 0424
Cell   917 710 8012
Lauren Franco
Home 203 268 2860
Cell   203 249 8016
Christopher Murray
Home 914 450 9512
Cell   914 450 9512

Rule: NASD Rule 3510(c)(5).
C. Regulators
We are a member of the Financial Industry Regulatory Authority (“FINRA”) and registered as a broker-dealer with the U.S. Securities and Exchange Commission (“SEC”).  We communicate with our regulators using the telephone, e-mail, fax, U.S. mail, and in person.  In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.
Rule: NASD Rule 3510(c)(9).
XI. Critical Business Constituents and Banks
A. Business constituents
We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of the internal or external SBD.  We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm.
Rules: NASD Rule 3510(c)(7).
B. Banks
We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need in light of the internal or external SBD.  The bank maintaining our operating account is:
The Bank of New York Mellon
101 Barclay Street, Floor 6E, New York, New York 10286
Stephen Rehm 212-815-4097 or Stephen.rehm@bnymellon.com
Rules: NASD Rule 3510(c)(7).
XII. Regulatory Reporting
Our firm is subject to regulation by FINRA and SEC.  We now file reports with our regulators via electronic means  In the event of an SBD, we will check with the SEC, FINRA, and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method.  In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.
FINRA
George Rodreguez, Senior Finance Coordinator
e-mail:  george.rodriguez@finra.com
mailing address:
FINRA, attn: George Rodriguez,
20 Board Street New York NY 10005
(646) 315 8657
SEC
Mark Schonfeld, Regional Director
e-mail: newyork@sec.gov
3 World Financial Center, Room 4300
New York, NY 10281
(212) 336-1100
Rule: NASD Rule 3510(c)(8).
XIII. Disclosure of Business Continuity Plan
South Street acts solely as dealer and does not maintain customer accounts.
If South Street changes its registration or business we will provide in writing a BCP disclosure statement to customers at account opening, as it is requested.  We also will mail it or send it electronically upon request.
Summary of the South Street Securities Business Continuity Plan
In the event of a Significant Business Disruption, South Street Securities LLC (“South Street”) will move our staff from our New York NY office site to our disaster recovery site.  South Street has contracted Matrix Applications LLC (“MatrixApps”) to provide immediate and comprehensive recovery support.  The telephone number for MatrixApps is (212) 803-5050.
South Street maintains back-ups of critical documents and data disk and computer tapes which are periodically moved from our primary and disaster recovery data centers and stored in a fire resistant facility.  When necessary, this data can be restored.
South Street has identified and made provision to recover all mission critical systems required to protect our business in the event of a disruption.  We have evaluated our relationships with our daily, critical, business support providers for phone and data transport, computer and network infrastructure, office equipment, and staffing, and have determined the extent that we can draw upon their services to help us recover our business. We feel confident that we can continue business if our home office is disrupted, or in the event of a major regional or national emergency.
Rule: NASD Rule 3510(e).
XIV. Updates and Annual Review
Our firm will update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm.  In addition, our firm will review this BCP annually, before December 31st, to modify it for any changes in our operations, structure, business, or location
Rule: NASD Rule 3510(b).