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Business Continuity Plan Customer Disclosure Statement

Fennel Financials LLC has developed a Business Continuity Plan (“BCP”) in order to guide 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.
Contacting Us – If, after a significant business disruption, you cannot contact us as you usually do, Fennel will ensure that information related to the disruption is made available on the Firm’s website at www.Fennel.com and may also be communicated through Fennel’s social media accounts. You may also contact us through our app and at (833)660-0680.
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 counterparty impact; regulatory reporting; and assuring customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, APEX has the ability for real-time backup capability of our important records in a geographically separate area. While every emergency situation 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 their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments as they occur. 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 those only affecting 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 plan to transfer our operations to a local site when needed and expect to recover and resume business as quickly as possible.
In a disruption affecting our business district, city, or region, we plan to transfer our operations to a site outside of the affected area and recover and resume business as quickly as possible. 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.
If the Securities Investor Protection (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 securities customers. We will assist the appointed trustee by providing our books and records identifying customer accounts subject to SIPC regulation.
Securities Investor Protection Corporation
805 15th Street, NW, Suite 800
Washington DC 20005-2207
202-371-8300
http://www.sipc.org/
For more information, or additional questions about our BCP, you can contact us at compliance@fennel-financials.com or (833) 660-0680.
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