Disclosures

Dynamex Trading LLC

2017 Business Continuity Plan (BCP) 

I. Emergency Contact Persons
Our firm’s two emergency contact persons are: Harris Bock, (w) 646-827-6033 or (c) 646-942-8630, harris.bock@dynamextrading.com, the Chief Executive Officer and Jason Lefkowitz, (w) 646-827-6074 or (c) 631-987-6253, jason.lefkowitz@dynamextrading.com, who is the Director of Sales Trading. These names will be updated in the event of a material change, and these will also be reviewed annually by the CEO.

II. Firm Policy 
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records. In the event that we determine we are unable to continue our business, we will assure our customers prompt access to their fills.  
 
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 a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption or any Act of God including a pandemic that could result in significant absenteeism, closings and slowdowns. 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
Harris Bock, CEO and a registered principal, is responsible for approving the plan and for conducting the required annual review.  Harris Bock has the authority to execute this BCP.

C. Plan Location and Access 
Our firm will maintain copies of its BCP and the annual reviews, and the changes that have been made to it for inspection. An electronic copy of our plan is circulated in email.

III. Business Description
Our firm conducts business primarily in options/equity execution for customers using an electronic platform and crossing with floor brokers. 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. Merrill Lynch clears and settles all trades and also maintains our accounts. Our firm services only institutional customers and we do not engage in any private placements. 
 
Our clearing firm is Merrill Lynch Professional Clearing Corporation, Bank of America Tower, One Bryant Park, New York, NY 10036 and our contact person at that clearing firm is Diego Villar, 312-347-3632, diego.villar@baml.com.

IV. Office Locations
Our firm is located at:
11 Broadway, Suite 360, New York, NY 10004
We have no other locations.
V. Alternative Physical Location(s) of Employees
Our firm has provided all key employees with VPN access. In the event of an SBD, all key employees will be able to access the system remotely from their home address or, if necessary, we will move our staff to Group One Trading, LPs office at 440 S. LaSalle Suite 3232, Chicago IL 60605, 
VI. Customers’ Access to Funds and Securities
We do not hold customers funds or securities.
VII. Data Back-Up and Recovery

Our firm maintains its primary electronic records in our New York office data center. Mike Clark, CFO, 415-283-3410, is responsible for the maintenance of these records.
 
Our firm maintains its back-up electronic records in our Chicago office data center. Mike Clark, CFO, 415-283-3410, is responsible for the maintenance of these records.
 
In the event of an internal or external SBD that causes the loss of our primary electronic records, we will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site.
VIII. 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 employees, critical business constituents, critical banks, critical counter-parties and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employee will include telephone, text, and email.
 
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. We will contact our clearing firm, critical banks and necessary regulators to apprise them of our financial status. If we determine that we may be unable to fund our operations, we will file appropriate notices with our regulators and immediately take the necessary steps to wind down operations.
IX. Mission Critical Systems
Our firm’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including entry, execution, comparison, allocation, clearance and settlement. We have primary responsibility for our mission critical function of order entry. Our clearing firm provides, through contract, the execution, comparison, allocation, clearance and settlement of securities transactions.

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 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 records at a remote site. 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. 

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.  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

Mike Clark 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
Currently, our firm enters orders by recording them electronically and sending them to our clearing firm electronically.
 
In the event of an internal or external SBD, we will enter and send records to our clearing firm by the fastest alternative means available.
B. Mission Critical Systems Provided by Our Clearing Firm
Our Clearing Firm is able to provide statements and copies of trades in the event of an SBD if necessary. 

X. Alternate Communications between the Firm and Customers, Employees, and Regulators 
A. Customers

Dynamex Trading has advised our customers that we will make all reasonable attempts to contact them during a SBD. We communicate with our customers using instant messenger over the Internet, the telephone, e-mail, fax, and in person.  In the event of a SBD, we will assess which means of communication are still available to us, and use the means available to communicate with our customers.  For example, if we have communicated with a party by instant messenger but the Internet is unavailable, we can call them on the telephone.
  
B. Employees


We now communicate with our employees using telephone, text and email. 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 to the means that we have used in the past to communicate with the other party.

C. Regulators

We are currently members of FINRA and Nasdaq. We communicate with our regulators using telephone, emails, fax, U.S. mail, and 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 to the means that we have used in the past to communicate with the other party.

XI. Critical Business Constituents, Banks, and Counter-Parties 
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 an SBD to them or our firm. 

XII. Regulatory Reporting
Our firm is subject to regulation by: FINRA, Nasdaq and the SEC. 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 FINRA, Nasdaq, the SEC and other regulators to determine which means of filing are still available to us, and use the means closest in speed and form to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.

XIII. Disclosure of Business Continuity Plan
Dynamex Trading has advised our customers that we will make all reasonable attempts to contact them during a SBD. We communicate with our customers using instant messenger over the Internet, the telephone, e-mail, fax, and in person.  In the event of a SBD, we will assess which means of communication are still available to us, and use the means available to communicate with our customers.  For example, if we have communicated with a party by instant messenger but the Internet is unavailable, we can call them on the telephone.

XIV. Updates and Annual Review
Our firm will update this plan whenever we have a material change to our operations, structure, business or location or 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.