Our clearing firm is [Wedbush
Securities, Inc, 1000 Wilshire Blvd., Los Angeles, CA 90017 Phone
www.wedbush.comand our contact person at that clearing firm is [Eve King, 1-213-688-4584,] Eve.email@example.com/ Jamie Carroll, 1-214-765-119] Jamie.Carroll@penson.com]. Our clearing firm has also given us the following alternative contact in the event it cannot be reached:Judy, 1-213-688-6737
IV. Office Locations
Our Location Office is located at 3452 E Foothill Blvd., Ste 1040, Pasadena, CA 91107, USA. Its main telephone number is 626-964-5966. Our employees travel to that office by means of car. We engage in order taking and entry at this location.
Alternative Physical Location(s) of
In the event of an SBD, we will
move our staff from affected offices to the closest of our unaffected
office locations. If none of our other office locations is available to
receive those staff, we will move them to Wedbush Morgan 1000
Wilshire Blvd., Los Angeles, CA 90017. Its main telephone number is
NASD Rule 3510(c)(6).
Customers’ Access to Funds and
Our firm does not maintain
custody of customers’ funds or securities, which are maintained at our
clearing firm, Wedbush Morgan. In the event of an
internal or external SBD, if telephone service is available, our
registered persons will take customer orders or instructions and contact
our clearing firm on their behalf, and if our Web access is available,
our firm will post on our Web site that customers may access their funds
and securities by contacting Wedbush Morgan 213-688-8000. The firms will make this information
available to customers through its disclosure policy.
If 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.
NASD Rule 3510(a); Securities Exchange Act
Rule 15c3-1; 15 U.S.C. 78eee (2003).
VII. Data Back-Up and Recovery (Hard Copy
Our firm maintains its primary hard copy books and records and its electronic records at [3452 E Foothill Blvd., Ste 1040, Pasadena, CA 91107]. [Michael Junhua. President/CEO 626-964-5966] is responsible for the maintenance of these books and records. Our firm maintains the following document types and forms that are not transmitted to our clearing firm: Our firm maintains its back-up hard copy books and records at [PSA PRIVATE STORAGE AREAS SPACE # F022 8000 ARTSON St. ROSEMEAD, CA 91770]. These records are paper copies. Michael JunHua Liao, President, 526-964-5966 is responsible for the maintenance of these back-up books and records. Our firm backs up its paper records by copying and taking them to our back-up site. We back up our records every month.
The firm backs up its electronic
records daily by utilizing Broker Insight, and keeps a copy at Wedbush Morgan
1000 Wilshire Blvd., Los Angeles, CA 90017. Also, by
In the event of an internal or
external SBD that causes the loss of our paper records, we will
physically recover them from our back-up site. If our primary site is
inoperable, we will continue operations from our back-up site or an
alternate location. For the loss of electronic records, we will either
physically recover the storage media or electronically recover data from
our back-up site, or, if our primary site is inoperable, continue
operations from our back-up site or an alternate location.
NASD Rule 3510(c)(1).
VIII. Financial and Operational Assessments
the event of an SBD, we will immediately identify what means will permit
us to communicate with our customers, 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.GlobaLinkusa.com 626-964-5966 and Michael JunHua Liao, cell
phone 626-674-1511. In addition, we will retrieve our key activity
records as described in the section
Data Back-Up and Recovery (Hard Copy and Electronic).
NASD Rules 3510(c)(3) & (f)(2).
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 clearing firm, critical banks, and 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 to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including having our Clearing firms’ facilitate all accounts obligations at Globalink Securities.
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, the maintenance of customer accounts, access to customer
accounts, and the delivery of funds and securities.
We have primary responsibility
for establishing and maintaining our business relationships with our
customers and have sole responsibility for our mission critical
functions of order taking and entry and execution. Our clearing firm
provides, through contract, the execution, comparison, allocation,
clearance and settlement of securities transactions, the maintenance of
customer accounts, access to customer accounts, and the delivery of
funds and securities.
Our clearing firm contract
provides that our clearing firm will maintain a business continuity plan
and the capacity to execute that plan. Our clearing firm represents
that it will advise us of any material changes to its plan that might
affect our ability to maintain our business and presented us with an
executive summary of its plan. In the event our clearing firm executes
its plan, it represents that it will notify us of such execution and
provide us equal access to services as its other customers. If we
reasonably determine that our clearing firm has not or cannot put its
plan in place quickly enough to meet our needs, or is otherwise unable
to provide access to such services, our clearing firm represents that it
will assist us in seeking services from an alternative source.
Our clearing firm represents
that it backs up our records at a remote site. Our clearing firm
represents that it operates a back-up operating facility in a
geographically separate area with the capability to conduct the same
volume of business as its primary site. Our clearing firm has also
confirmed the effectiveness of its back-up arrangements to recover from
a wide scale disruption by testing.
Recovery-time objectives provide
concrete goals to plan for and test against. They are not, however,
hard and fast deadlines that must be met in every emergency situation,
and various external factors surrounding a disruption, such as time of
day, scope of disruption, and status of critical
infrastructure—particularly telecommunications—can affect actual
recovery times. Recovery refers to the restoration of clearing and
settlement activities after a wide-scale disruption; resumption refers
to the capacity to accept and process new transactions and payments
after a wide-scale disruption. Our clearing firm has the following SBD
recovery time and resumption objectives: recovery time period of
within 24 hour and resumption time of within the same business
Our Firm’s Mission Critical Systems
1. Order Taking
Currently, our firm receives
orders from customers via telephone and online orders at our Web site at
www.globalinkusa.com, in person visits by the customer. During an
SBD, either internal or external, we will continue to take orders
through any of these methods that are available and reliable, and in
addition, as communications permit, we will inform our customers when
communications become available to tell them what alternatives they have
to send their orders to us. Customers will be informed of alternatives
by telephone. If necessary, we will advise our customers to place
orders directly with our clearing firm at
Wedbush Morgan 213-688-8000.
2. Order Entry
Currently, our firm enters
orders by recording them electronically and sending them to our clearing
firm electronically or telephonically. Alternatively, We place
customer orders through Broker Insight and Orbis Trader. We have contacted
Broker Insight/Orbis and were told that, under its BCP, we can expect
services within 24 hours.
In the event of an internal SBD,
we will enter and send records to our clearing firm by the fastest
alternative means available, which include telephone orders. In the
event of an external SBD, we will maintain the order in electronic or
paper format, and deliver the order to the clearing firm by the fastest
means available when it resumes operations. In addition, during an
internal SBD, we may need to refer our customers to deal directly with
our clearing firm for order entry.
3. Order Execution
We currently execute orders by
using Broker Insight and Orbis Trader online system. In the event of an internal SBD, we
would telephone orders to clearing firms’ trading desk.In the event of
an external SBD, we would continue to telephone all orders to our
clearing firms’ trading desk.
Mission Critical Systems Provided by
Our Clearing Firm
Our firm relies, by contract,
on our clearing firm to provide order execution, order comparison, order
allocation, and the maintenance of customer accounts, delivery of funds
and securities, and access to customer accounts.
NASD Rules 3510(c) & (f)(1).
X. Alternate Communications Between the
Firm and Customers, Employees, and Regulators
We now communicate with our
customers using the telephone, e-mail, our Web site, fax, U.S. mail, and
in person visits at our firm or at the other’s location. 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.
NASD Rule 3510(c)(4).
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: Michael JunHua Liao
Steven Fan, Bill Liau, Claire Tang and Setven Thornton
NASD Rule 3510(c)(5).
We are currently members of the
following SRO, FINRA and SIPC. We communicate with our regulators using
the telephone, fax, and U.S. mail. 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.
NASD Rule 3510(c)(9).
XI. Critical Business Constituents, Banks,
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.
NASD Rule 3510(c)(7).
contacted our banks 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:
Far East National Bank, City of
Industry Office 17851_B Colima Road City of Industry, CA 91747..
NASD Rule 3510(c)(7).
have contacted our critical counter-parties, such as other
broker-dealers or institutional customers, to determine if we will be
able to carry out our transactions with them in light of the internal or
external SBD. Where the transactions cannot be completed, we will work
with our clearing firm or contact those counter-parties directly to make
alternative arrangements to complete those transactions as soon as
NASD Rules 3510(a) &(c)(7).
XII. Regulatory Reporting
Our firm is subject to regulation by the SEC, State SEC and FINRA. We now file reports with our regulators using paper copies in the U.S. mail, and electronically using fax, e-mail, and the Internet. 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.
NASD Rule 3510(c)(8).
XIII. Disclosure of Business Continuity Plan
We provide in writing a BCP
disclosure statement to customers at account opening. We also post the
disclosure statement on our Web site and mail it to customers upon
Rule: NASD Rule 3510(e).
XIV. Updates and Annual Review
NASD Rule 3510(b).
Senior Manager Approval
I have approved this Business Continuity Plan as reasonably designed to
enable our firm to meet its obligations to customers in the event of an
NASD Rule 3510(d).
Signed: Junhua Michael Liao