BUSINESS CONTINUITY PLAN
EquiLend’s Business Continuity and Contingency Planning Disclosure Statement
EquiLend Holdings LLC and its operating subsidiaries, including EquiLend LLC, EquiLend Europe Limited, EquiLend Limited, EquiLend Canada Corp, Automated Equity Finance Markets, Inc. and DataLend LLC (collectively, "EquiLend"), have developed, implemented and maintain a comprehensive business continuity plan and program (the “BCP”) that is reasonably designed to address a variety of emergencies and incidents that may result in a significant disruption to their respective businesses. The BCP is reviewed, tested and updated on a regular basis and is designed to protect the interests of our customers, the health and safety of our staff, provide for the continuation of essential business operations and services, and ensure as rapid a recovery of operational systems as reasonably possible in the event of an unforeseen and/or sudden disaster or significant business disruption (“SBD”) impacting our facilities, infrastructure, services and personnel.
Since the timing and impact of disasters and SBD incidents and/or events is inherently unpredictable, we retain the ability to be flexible in our response as such incidents and/or events occur. Whereas we cannot predict with certainty the probability or impact of any or all potential disaster and SBD incidents and/or events, the BCP has been developed to reasonably address known and knowable probable disasters and SBD incidents and/or events caused by natural disasters, power outages, epidemiological public health emergencies and other scenarios that are reasonably foreseeable in light of our businesses as at the date of the approved written version of the BCP.
Examples of potential changes to our regular business operating procedures resulting from a disaster or SBD:
- In the event a disaster or SBD incapacitates our primary physical office location in New York, we will transfer our client service functions and business operations to our physical offices located in London and/or Dublin, or to one or more remote sites located in the United States. All global EquiLend staff have the ability to work remotely from multiple locations, including from their homes, which will allow for the continuation of service to our clients should staff be unable to access any one given physical office site location.
- In the event a disaster of SBD incapacitates any of our other office locations, we will transfer client support and business operations of the affected office location to one or more of our non-affected office locations.
- In the event a disaster or SBD affects our primary production data center facility in Carteret, New Jersey, USA, operation of the EquiLend securities lending platform (the "Platform") will be transferred to our disaster recovery data center facility in Houston, Texas.
- We do not anticipate that power outages at the primary production data center facility will require us to transfer operation of the Platform to the disaster recovery data center facility, as our primary production data center facility maintains a supplemental power supply (UPS). The facility additionally maintains alternative power generation capabilities (i.e., battery and diesel generation), which can support the needed operations for a significant period of time.
- Our production data is maintained within our primary data center production facility in Carteret, New Jersey, USA. We additionally maintain copies of our production data in our disaster recovery data center facility in Houston, Texas, USA.
No contingency plan can eliminate all risk of a service interruption or temporarily impaired access to the Platform. We will evaluate and revise our BCP to address disruption risks to the extent reasonably practicable with reference to all applicable legal and regulatory requirements as potential business impairing developments occur.
We have made certain assumptions regarding the availability and accessibility of alternative facilities and skilled personnel in developing our BCP, including as pertains to the continuing availability of a sufficient number of our skilled personnel necessary to operate our systems and to work with external organizations, and for applicable securities markets and relevant government agencies continuing to be operational and/or accessible. If these assumptions prove to be invalid or impracticable under any given disaster or SBD incident and/or event, then we will evaluate reasonable actionable alternative options designed to minimize the resulting disruption to our services at such time.
Updates and Access to the BCP
We will continue to update the BCP as needed in the event of changes to our business processes, technology and staff and will continue to post updated BCP information on our website at: https://www.equilend.com/business-continuity-plan/
EquiLend clients may request to review the BCP. We have adopted an “access equals delivery” protocol regarding our BCP as applicable to our regulatory delivery obligations. Accordingly, client access to the BCP will be permitted solely via pre-approved chaperoned video conferencing with the EquiLend IT Security and other applicable staff upon written request to:
EquiLend Holdings LLC
ATTN: Business Continuity Plan
225 Liberty Street, 10th Floor
New York, New York 10281