Disclosures

Business Continuity Management

At Piper Sandler, we are committed to guiding you on your financial journey and helping you reach your investment goals. To ensure your journey goes smoothly, we are careful to plan for any unexpected events that may affect you or your accounts with us. We prepare for these unexpected events through a number of processes. 

We have an ongoing and comprehensive business continuity management (BCM) program in place intended to help us respond to and recover from a business disruption. The BCM program coordinates all our business disruption preparation efforts, including impact identification and analysis, business continuity plan development and testing, crisis management and training.

Piper Sandler BUSINESS CONTINUITY PLAN

We developed the business continuity plan to protect the interests of our clients, shareholders and employees, and to support the recovery of our core businesses. All areas of the company have documented continuity plans that identify their core functions and the resources required to conduct them. Each plan accounts for the following general scenarios:

Our responses to each of these scenarios will depend on the external variables associated with the disruption (the time of day and the extent of the disruption, for example), but may include transferring functions to alternate sites or activation of and relocation to our disaster recovery sites.

BACK-UP FACILITIES AND ARRANGEMENTS

Piper Sandler has taken a series of steps to ensure that adequate redundancy is in place to provide resilience during a disruption. We have focused on key technology infrastructure and strategic third-party vendors to support recovery of our core functions. Some of the methods we use include:

Our firm conducts business in retail sales, institutional sales, investment banking, fee-based business, fixed income, and derivative securities. Our firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders, execute and allocate transactions which are routed to our clearing firm, which clears and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and deliver funds and securities. Our firm services retail and institutional customers and makes markets. Our Trading and Sales desks are located in multiple offices across the US. Our clearing firm is: Pershing LLC, a division of Bank of New York Mellon.

Our firm relies, by contract, on our clearing firm to provide trade clearance and settlements and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts. 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 provides 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 customer records. 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, and it has confirmed that it tests its back-up arrangements four times a year. 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.