Business Continuity Plan
for
Park 10 Financial, LLC
June 2021

Emergency Contact Persons

Our firm’s two emergency contact persons are:

Randall Fielder, President and Chief Compliance Officer of Park 10 Financial, LLC who can be reached at 713-256-9047 or randall@park10financial.com

Lindsey Savage, Chief Operations Officer of Park 10 Financial, LLC who can be reached at 281 912-8801 or Lindsey@park10financial.com

Firm Policy

Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding our employees’ lives and our firm’s property, making a financial and operational assessment, quickly recovering, and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. If we determine we are unable to continue our business; we will assure our customers prompt access to their funds and securities.

A.     Significant Business Disruptions (SBDs)

Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of the securities markets or several firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

B.   Approval and Execution Authority

Randall Fielder President, a registered principal, is responsible for approving the plan and for conducting the required annual review. Lindsey Savage has the authority to execute this BCP.

C.   Plan Location and Access

Our firm will maintain copies of its BCP plan and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is located on Sync.Com in the Park 10 folder name BCP.

II.    Business Description

Our firm conducts business in equity and fixed income 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. All transactions are sent to our clearing firm, which executes our orders, compares them, allocates them, clears, and settles them. Our clearing firm also maintains our customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services only retail customers. We do not engage in any private placements. 

Our clearing firm is Folio Institutional 8180 Greensboro Dr 8^th Floor McLean, VA 22102-3865, 1-888 230-5635, support@folioinvesting.com , www.folioinstitutional.com  and our contact person at that clearing firm is Patrick Forde 571 340-2294 patrick.ford@gs.com. Our clearing firm has also given us the following alternative contact in the event it cannot be reached:

Robyn Wood, 571 666-0695  Robyn.wood@gs.com , www.folioinstitutional.com

III.    Office Location

Our Location #1 Office is located at 1400 Broadfield Blvd Suite 200 Houston, TX 77084 713-955-3555. Its main telephone number is 713-955-3555. Our employees may travel to that office by means of car. We engage in order taking and entry at this location.

IV.     Alternative Physical Location(s) of Employees

List the alternate physical location(s) your firm will use in the event an SBD affects the operation of your office locations.

In the event of an SBD, we will move our staff from affected office(s) to the closest of our unaffected office location(s). If none of our other office locations is available to receive those staff, we will move them to 1610 E Sonterra Blvd, San Antonio, TX 78258. Its main telephone number is 210 545-2810.

V.      Customers’ Access to Funds and Securities

State that your firm does not maintain custody of customers’ funds or securities and how your firm will make them available to customers in the event of an SBD. State the entity at which such funds and securities are held and how your firm will facilitate access to them. Describe any relationship between your firm’s ability to grant customer access to funds and securities and Securities Investor Protection Corporation (SIPC) regulations on the disbursement of funds and securities.  

Our firm does not maintain custody of customers’ funds or securities, which are maintained at our clearing firm, Folio Institutional. In the event of an internal or external SBD, if telephone service is available, our registered persons will take customer orders or instructions and contact our clearing firm on their behalf, and if our Web access is available, our firm will post on our website that customers may access their funds and securities by contacting Folio Institutional. The firm will make this information available to customers through its disclosure policy. 

If SIPC determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist SIPC and the trustee by providing our books and records identifying customer accounts subject to SIPC regulation.

Rules: FINRA Rule 4370(a); Securities Exchange Act Rule 15c3-1; see also 15 U.S.C. § 78eee.

VI.   Data Back-Up & Recovery (Hard Copy and Electronic)

Our firm maintains its primary hard copy books and records and its electronic records at Redtailtechnology.com, These records are Worm electronic copies. Other records are store at www.sync.com, in electronic format. Lindsey Savage is responsible for the maintenance of these books and records. Our firm maintains the following document types and forms that are not transmitted to our clearing firm: Account Information form, Advisory Agreement Contract, ADV, 401 K Rollover Options Disclosure form, Financial Planning Agreement.

Our firm maintains its back-up hard copying books and records at the above sites.  These records are paper copies. Lindsey Savage Chief Operations Officer is responsible for the maintenance of these back-up books and records. Our firm backs up its paper records by copying and taking them to our back-up site.

In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our back-up sites. If our primary site is inoperable, we will continue operations from our back-up sites or an/or alternate location. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up sites and continue operations from alternative location.

VII.       Financial and Operational Assessments

A.   Operational risk

 In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counterparties, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include www.Park10financail.com 713 955-3555, secure email. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic).

B.   Financial and Credit Risk

In the event of an SBD, we will determine the value and liquidity of our investments and other assets to evaluate our ability to continue to fund our operations and remain in capital compliance. If we determine that we may be unable to meet our obligations or otherwise continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps.

VIII.   Mission Critical Systems

Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of 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.

We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions of order taking and entry and execution. Our clearing firm provides, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions, maintenance of customer accounts, access to customer accounts and the delivery of funds and securities. 

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. In the event our clearing firm executes its plan, it represents that it will notify us of such execution and provide us equal access to services as its other customers.

Our clearing firm represents that it backs up our 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. 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, and various external factor surrounding a disruption, such as time of day, scope of disruption and status of critical infrastructure—particularly telecommunications—can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments after a wide-scale disruption.

Lindsey Savage will periodically review our clearing firm’s capabilities to perform the mission critical functions the clearing firm has contracted to perform for our firm.

A.   Our Firm’s Mission Critical Systems

     1.   Order Taking

Currently, our firm receives orders from customers via telephone, in-person visits by the customer or telephoning the custodian. During an SBD, either internal or external, we will continue to take orders through any of these methods that are available and reliable, and in addition, as communications permit, we will inform our customers when communications become available to tell them what alternatives they must send their orders to us. Customers will be informed of alternatives by telephone, email, or regular mail. If necessary, we will advise our customers to place orders directly with our clearing firm at www.Folio Investing.com or contacting them via 888 230-5635. 

     2.   Order Entry

Currently, our firm enters orders by recording them on paper and electronically and sending them to our clearing firm electronically or telephonically.

In the event of an internal SBD, we will enter and send records to our clearing firm, which include electronically, telephonically. In the event of an external SBD, we will maintain the order in electronic or paper format and deliver the order to the clearing firm by the fastest means available when it resumes operations. In addition, during an internal SBD, we may need refer our customers to deal directly with our clearing firm for order execution. 

     3.   Order Execution

We currently execute orders electronically, and telephonically. In the event of an internal SBD, we would execute orders electronically, and telephonically or refer our customers to deal directly with our clearing firm for order execution.  In the event of an external SBD, we would execute orders electronically, and telephonically or refer our customers to deal directly with our clearing firm for order execution.

     4.   Other Services Currently Provided to Customers

In addition to those services listed above in this section, we also provide customers tax documents, or inquiries of their account balance, etc. In the event of an internal SBD, we would refer our customers to deal directly with our clearing firm.  In the event of an external SBD, we would refer our customers to deal directly with our clearing firm.

B.   Mission Critical Systems Provided by Our Clearing Firm

Describe the arrangements you have with your clearing firm to provide other mission critical systems.

Our firm relies, by contract, on our clearing firm to provide [order execution], order comparison, order allocation, customer account maintenance and/or access and delivery of funds and securities. 

IX.   Alternate Communications Between the Firm and Customers, Employees, and Regulators

     A.  Customers

We now communicate with our customers using, the telephone, email, our website, U.S. mail and in-person visits at our firm. In the event of an SBD, 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 email but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail. 

     B.  Employees

We now communicate with our employees using telephone, email, and in person, etc. In the event of an SBD, 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. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers. We have identified persons, noted below, who live near each other and may reach each other in person:

The person to invoke use of the call tree is:

C.   Regulators

We are currently regulated by federal and state securities regulators. We communicate with our regulators using, telephone, email, U.S. mail, in person. In the event of an SBD, 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.

X.  Critical Business Constituents, Banks, and Counterparties

A.   Business constituents

We have contacted our critical business constituents’ businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services, and determined the extent to which we can continue our business relationship with them considering the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm. Our major suppliers are: CRM, Document Storage Redtail Technologies (800) 291-3500, 3131 Fite Circle Sacramento, CA 95827, Sync.com Inc.855-367-7962, 105-155 Gordon Baker Road Toronto, ON M2H 3N5, Nationwide Advisory Solutions 10350 Ormsby Park Place Lewisville, KY 40223, 502-515-7838, Wildej4@nationwide.com, Hushmail.com 1 877-533-4874, 580-Hornby St. Suite 360 Vancouver VC, V6C3B6 Canada.

Banks:

We have contacted our banks and lenders to determine if they can continue to provide the financing that we will need considering the internal or external SBD. The bank maintaining our operating account is Wells Fargo Bank 6990 Hwy 6 N. Houston, Tx 77084, 281 855-0574, Ms. Ardon

XI.           Regulatory Reporting

Describe how your firm will file its regulatory reports in the event of an SBD.  

Our firm is subject to regulation by: State of Texas, we now file reports with our regulators using paper copies in the U.S. mail, and electronically using fax, email, and the Internet. In the event of an SBD, we will check with the SEC, FINRA and other regulators to determine which means of filing are still available to us and use the means closest in speed and form (written or oral) to our previous filing method. If we cannot contact our regulators, we will continue to file required reports using the communication means available to us. Texas State Securities Board 208 E.10^th St. Austin, Tx 78701 512 305-8301.

XII.         Disclosure of Business Continuity Plan

Attached is our written BCP disclosure statement we provide customers via email or us postal mail, upon request.  We also post the disclosure statement on our website and mail it. 

XIII.      Updates and Annual Review

Our firm will update this plan whenever we have a material change to our operations, structure, business, or location or to those of our clearing firm. In addition, our firm will review this BCP annually, to modify it for any changes in our operations, structure, business, or location or those of our clearing firm.

XIV.    Senior Manager Approval 

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.   

Signed:            _____Randall Fielder___

Title:                _____President/CCO_____

Date:               _______6/20/2021_______

Attachment A to Park 10 Financial, LLC Business Continuity Plan

Park 10 Financial, LLC’s Business Continuity Planning

Park 10 Financial, LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. 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 information on our business continuity plan.

Contacting Us – If after a significant business disruption, you cannot contact us as you usually do at 713 955-3555, randall@park10financial.com, at info@park10financial.com. you should call our alternative number 713 256-9047 or go to our website www.park10financial.com. If you cannot access us through either of those means, you should contact our clearing firm number at 888-230-5635 at www.folioinstitutional.com for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash and security transfer transactions for your customers]. 

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 significant business disruption. 

Our business continuity plan addresses: data backup 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 assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, Folio Institutional backs up our important records in a geographically separate area. While every emergency poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions:  Your orders and requests for funds and securities could be delayed during this period. 

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 5 business days. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and recover and resume business within 5 business days. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our website www.Park10financial.com  or our customer emergency number, 713 256-9047. how to contact us. 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.

For more information – If you have questions about our business continuity planning, you can contact us at Park10 Financial at info@park10financial.com.