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).

Contacting Us.  If after a significant business disruption you cannot contact us as you usually do, you may call any of our offices, which are listed at our website at www.viningsparks.com.  To receive up-to-date information during a significant business disruption, Customers may call the Vining Sparks main emergency telephone numbers, which are (901) 766-3000 and 800-829-0321.

Our Business Continuity Plan.  We plan to quickly recover and resume business operations after a significant business disruption 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 business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the disruption.

Vining Sparks has taken significant steps to mitigate the impacts of business interruptions resulting from a wide variety of potential events, including the loss of key facilities and resources.  Our business continuity plan 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; and regulatory reporting.

Vining Sparks is a self-clearing broker/dealer and, as such, it is able to receive and execute securities transactions. Consistent with its business continuity plan, Vining Sparks maintains back-up facilities in geographic locations separate from its primary facilities. Using these back-up facilities, Vining Sparks intends to continue its business in the event of a significant business disruption.

The following describes specific disruption events and Vining Sparks intended corresponding general business continuation responses to those events. Customers, however, should note that these responses are subject to modification and, depending on the severity of a specific event, Vining Sparks cannot guarantee that it will follow the stated course of action. If these responses are modified, Vining Sparks  will post the updated disclosure statement on its emergency information website. In the alternative, Customers may request that Vining Sparks send them, by mail, a copy of the updated disclosure statement.

A Disruption to a Single Building

In the event of a significant business disruption to a single building, this disruption may be caused by physical damage, technology problems, or an inability to have personnel arrive at the office. Because some buildings, such as the home office, are more critical to Vining Sparks, our ability to resume business following a disruption to a specific building depends on the building affected. If the location is unusable, Vining Sparks has duplicative systems that will be run from a separate building. If there is a disruption to the home office, Vining Sparks expects that operations could be disrupted for up to one (1) day.

A Firm-Only Business Disruption

In the event of a significant business disruption to Vining Sparks’ internal primary systems, we will transfer operations to its back-up facilities. In this process, Customers may experience a delay in reaching Vining Sparks due to increased telephone calls, technology delays, or other difficulties arising from the transfer of operations.  In this event, Vining Sparks expects that operations could be disrupted for up to one (1) day.

A Business-District, Citywide, or Regional Disruption

In the event of a significant business disruption that affects the business district, city, or region where any of Vining Sparks’ primary systems are located, Vining Sparks will leverage its national footprint to transfer its operations to back-up facilities. Redirection of main telephone numbers will provide customers with the ability to reach the recovery site. In this process, Customers may experience a delay in reaching Vining Sparks due to increased telephone calls, technology delays, or other difficulties arising from the transfer of operations. In this event, Vining Sparks expects that operations could be disrupted for up to three (3) days.

For more information.  If you have questions about our business continuity planning, you can contact us at 901-766-6360 or at itdirector@viningsparks.com.