State Street Global Markets, LLC's (SSGM) policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making financial and operational assessments, recovering and resuming operations as quickly as possible, protecting the firm’s books and records, and allowing our customers to continue to transact business. And, in the event that we determine we are unable to continue our business, we will make every effort to provide prompt access by customers to their funds and securities.
In order for SSGM to continue operations, we rely on the systems and processes established and implemented by State Street Corporation. Risk assessment, defined protocols for managing events, written procedures, offsite storage, established alternative sites, and testing are critical components of State Street Corporation’s continuity planning process. Our goal is to ensure our data processing systems, data communications facilities, information, data and business functions can be restored in a secure manner and that restoration is accomplished in a time frame consistent with legal, regulatory and business requirements while maintaining information integrity.
SSGM’s Business Continuity Plan ("Plan") is made up of Business Continuity Plans for various Business Units, developed in accordance with the requirements of State Street Corporation’s Business Continuity requirements that provide functions, systems or services to SSGM. Specifically, these business areas include, but are not limited to, trading, sales, operations and IT.
Summary of Our Business Continuity Plan
SSGM’s Business Continuity Plan ("Plan") provides specific responses and procedures that address three scenarios of varying severity (e.g., system unavailable; site or location unavailable; and system and site/location unavailable).
SSGM’s Plan has procedures that are designed to continue SSGM’s business operations during each of the three scenarios and, for each process and system that SSGM utilizes, our planned recovery time and alternative/back-up that will be used, if necessary. Expected recovery times for mission critical systems average up to 24 hours.
SSGM has primary responsibility for establishing and maintaining our business relationships with our customers and has sole responsibility for most mission critical systems. SSGM also engages in relationships with clearing firms, through contract or other agreement, to maintain other mission critical systems. If during an SBD, SSGM determines that a clearing firm has not or cannot put their business continuity plan in place quickly enough to meet our needs, or are otherwise unable to provide access to their services, SSGM will seek assistance from the clearing firm in obtaining services from an alternative source. SSGM's primary clearing firms are National Financial Services LLC, Bear Stearns and Pershing.
SSGM’s Plan contains procedures for communicating with internal and external parties, including our customers, during activation of the Plan. In the event that a portion of the Plan is activated in any of the representative business units, 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.
SSGM’s Plan contains procedures that include, where applicable, alternative electronic processes, manual procedures and alternative back-up facilities (in the event a specific location needs to be relocated).
Notification About Our Plan
SSGM’s Plan Summary (contained herein) will be provided to Customers at the time an account is opened with SSGM.
Disclaimer
SSGM’s Plan is a real-time document and is therefore subject to modifications without notification. Updated summaries of SSGM’s Plan may be obtained by requesting a copy by mail to the address below or can be obtained electronically at www.ssgafunds.com, or www.streettracks.com
State Street Global Markets, LLC
Business Continuity Plan Summary
P.O. Box 5502
Boston, MA 02206-5502
