ICBA Securities

Business Continuity Plan

Vining Sparks is providing this document to inform you of its ability to respond to events that could cause business disruptions.  Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.  With that in mind, we are providing you with this overview of Vining Sparks’ Business Continuity Plan (BCP).

 

Emergency Contact Persons

James Reber, CEO 901-262-1353
jreber@icbasecurities.com

Carol Ann Kinzer, FINOP 678-525-0992
ckinzer@icbasecurities.com

The firm will provide FINRA with contact information for the two emergency contact persons: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile number through the FINRA Contact System (FCS). ICBA will promptly notify FINRA of any change in this information through FCS (but no later than 30 days following the change) and will review, and if necessary, update, this information within 17 business days after the end of each calendar year.


Firm Policy

ICBA will 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, and protecting all of the firm’s books and records. If the firm determines it is unable to continue business, proper notification will be made to regulators and business constituents.

  • Significant Business Disruptions (SBDs)

    The BCP anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the ability to communicate and do business, such as a fire in the 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. The firm’s response to an external SBD relies more heavily on other organizations and systems. While ICBA does not have customers or conduct a securities business, certain books and records are stored and maintained by other entities.

  • Approval and Execution Authority

    James Reber, the CEO, is responsible for approving the plan and conducting the required annual review. Mr. Reber has the authority to execute this BCP.

  • Plan Location and Access

    ICBA will maintain copies of the BCP plan and annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is stored electronically on a Vining Sparks network server, which is backed up to a data center located in Dallas.


Business Description

ICBA engages in only one type of business activity. The firm refers members of Independent Community Bankers of America to Vining Sparks, IBP, LP, for a referral fee. (Vining Sparks is a broker-dealer located in Memphis, Tennessee). The firm does not engage in a securities business and does not have customers. As such, ICBA does not hold customer funds or securities. ICBA’s business activities do not require a clearing relationship.


Office Locations

ICBA Securities is located at 775 Ridge Lake Blvd., Suite 175, Memphis, TN 38120. The main telephone number is 901-762-5880. Employees may travel to the office by foot or car. Currently, there are no other branch offices.


Alternative Physical Location(s) of Employees

In the event of an SBD, ICBA employees will work from their homes. Both registered individuals have internet access and can communicate with regulators and business constituents from their home offices.


Customers’ Access to Funds and Securities

ICBA does not have customers or maintain custody of customers’ funds or securities. The firm refers members of Independent Community Bankers of America to Vining Sparks, IBP, LP, for a referral fee.


Data Back-Up and Recovery (Hard Copy and Electronic)

ICBA maintains its primary hard copy books and records and its electronic records at 775 Ridge Lake Blvd., Memphis, TN 38120. James Reber is responsible for the maintenance of these books and records. The firm maintains financial statements, communications, promotional material, and employee records at this location.

Electronic records are backed up daily to Vining Sparks servers located at 775 Ridge Lake Blvd., Memphis, TN. (ICBA and Vining Sparks are parties to a Program Agreement under which certain services, including data back-up, are provided by Vining Sparks, IBG, LP.) Vining Sparks servers backed up nightly and replicated in real time to a Data Recovery site in Dallas.

If the firm’s primary site is inoperable, operations will continue from registered persons’ homes. For the loss of electronic records, data will be electronically recovered from the back-up site.


Financial and Operational Assessments

  • Operational Risk

    In the event of an SBD, the firm will immediately identify what means will permit communication with regulators, business constituents, employees, and critical banks. Although the effects of an SBD will determine the means of alternative communication, the communications options the firm will employ will include telephone voice mail and secure email. In addition, the firm will retrieve key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).

  • Financial and Credit Risk

    In the event of an SBD, the firm will determine the value and liquidity of its assets to evaluate its ability to continue to fund operations and remain in capital compliance. If ICBA determines that it may be unable to continue to fund operations, additional financing will be requested from the parent organization or one of its banks. If a capital deficiency cannot be remedied, appropriate notices will be filed with regulators and immediately action will be taken to cease business operations.


Mission Critical Systems

ICBA does not conduct 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.

Business activities are limited solely to referring members of Independent Community Bankers of America to Vining Sparks, IBP, LP, for a referral fee. The firm does not have customers.


Alternate Communications Between the Firm and Employees and Regulators

  • Customers

    ICBA does not conduct 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.

    Business activities are limited solely to referring members of Independent Community Bankers of America to Vining Sparks, IBP, LP, for a referral fee. The firm does not have customers.

  • Employees

    ICBA currently communicates with employees using telephone, email, and in person. In the event of an SBD, ICBA will assess which means of communication are still available and use the means closest in speed and form (written or oral) to the means used in the past to communicate with the other party. As there are only two individuals registered with the firm, no call tree is necessary. Mr. Reber and Ms. Kinzer have each other’s contact information and will reach out to the other party during an SBD.

  • Regulators

    ICBA is currently a member of FINRA and MSRB. The firm is also regulated by the Securities and Exchange Commission and the securities commissions of Arkansas, California, Colorado, District of Columbia, Florida, Kansas, Minnesota, Missouri, New Jersey, New York, Tennessee, Texas, and Washington. The firm will communicate with regulators by telephone, fax, email, or U.S. mail. In the event of an SBD, ICBA will assess which means of communication are still available and use the means closest in speed and form (written or oral) to the means used in the past to communicate with the other party.


Critical Business Constituents, Banks, and Counter-Parties

  • Business constituents

    ICBA contacted critical business constituents (businesses with which it has an ongoing commercial relationship in support of operating activities, such as vendors providing critical services), and determined the extent to which business relationships can continue in light of an internal or external SBD. ICBA will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when the firm needs them because of a SBD to them or ICBA. ICBA’s major suppliers are Vining Sparks IBG, LP and Pagefreezer. (ICBA’s email archiving and data back-up services are provided by Vining Sparks.)

  • Banks

    ICBA’s primary bank accounts are with Landmark Community Bank, whose office is in Memphis, TN (901-260-2500), and Fidelity Bank in West Memphis, Arkansas (870-735- 8700). If ICBA’s banks are unable to provide the financing necessary to continue operations, ICBA will seek alternative financing immediately from its parent organization.


Regulatory Reporting

ICBA is subject to regulation by FINRA, the SEC and the securities commissions of Arkansas, California, Colorado, District of Columbia, Florida, Kansas, Minnesota, Missouri, New Jersey, New York, Tennessee, Texas, and Washington. The firm now files reports with regulators electronically using fax, email and the Internet. In the event of an SBD, ICBA will check with the SEC, FINRA and other regulators to determine which means of filing are still available and use the means closest in speed and form (written or oral) to the previous filing method. If ICBA cannot contact regulators, the firm will continue to file required reports using the communication means available.


Disclosure of Business Continuity Plan

This Business Continuity Plan is available upon request to regulators and business constituents. Since the firm has no customers, a disclosure statement was not prepared.


Updates and Annual Review

ICBA will update this plan when there is a material change to the firm’s operations, structure, business, or location. In addition, the firm will review this BCP annually to modify it for any changes in operations, structure, business, or location.