Business Continuity Plan and Disclosure Statement
Spearhead Capital, LLC plans to quickly recover and resume business operations after a significant business disruption (SBD) 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 company’s business continuity plan (BCP) is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD.
The BCP addresses: data back up 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 counter-party impact; regulatory reporting; and facilitating prompt access to customer funds and securities if we are unable to continue our business.
The placement issuers maintain all records related to your investments and account holdings and backs up important records in accordance with their business continuity plan. For more information on their contingency plan, please contact the sponsor or issuer directly at the telephone number provided on your offering documents or through their website.
Significant Business Disruptions: The Company’s plan takes into account two kinds Significant Business Disruptions, internal and external. Internal SBDs affect only the Company’s ability to communicate and do business, such as a fire or loss electrical power in the office or building.
External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes a wide-scale, regional disruption in essential services.
Internal SBDs: In the event of a disruption in the Company’s business operations due an internal SBD, the Company will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available), such as the Internet, cell phones, etc., or by moving our operations to an alternative location.
If personnel or operations must be moved to an alternate location, the Company anticipates that it will resume regular operations with 2-4 hours.
External SBDs: In the event of a disruption in the Company’s business operations due to an external SBD, the Company will attempt to continue to conduct business as usual by moving its operations to an alternative location outside the effected area, if possible, or by providing customers with alternative communication arrangements, as indicated below, to conduct business or to access information regarding their funds and securities.
The Company will attempt to resume business within 24-48 hours and to keep its customers informed regarding relevant events to the best of its ability based on the circumstances.
In all cases, the Company will resume normal business operations as soon as it is able to do so, based on the type and the extent of the disrupting event.
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.
Communications: In the event you are unable to reach the Company at our main number, please proceed as follows:
- Contact the Company at the following alternate telephone number: (917) 287-4808
- Access the Company’s website at www.spearheadllc.com
- Contact the clearing firm directly at one of the following telephone numbers to process transactions or for information on your holdings: N/A
- Contact the product sponsor directly at the number listed on your most recent statement.
- Contact the private placement issuer directly at the number listed on applicable offering documents.
- Access the clearing firm, product sponsor or issuer website for more information on contacting this entity and their business continuity plans. The website address can generally be found on your statement or offering documents.
- Contact the FINRA’s District office at the following telephone number for more information on the company’s status and additional instructions: (561) 443-8000
Contact information: Any questions regarding the Company’s Business Continuity Plans should be addressed to: Alyson Kest, Chief Compliance Officer & Deputy General Counsel, 12012 South Shore Blvd., Suite 112, Wellington, FL 33414, or call (561) 801-7302.