In the event of an emergency or significant business disruption, the principals of Kahn Brothers Group, Inc. and its subsidiary and affiliated companies (collectively “the Firm”) will have access to clients' account information through the Firm’s internal portfolio system and custodian trading platform, both of which are available remotely. The internal portfolio system is also backed up daily from our server to three separate back up facilities that reside in geographically diverse locations.
Pershing LLC, a subsidiary of The Bank of New York Mellon Corp., is the clearing agent for Kahn Brothers Group Inc.’s subsidiary broker-dealer, Kahn Brothers LLC. As such, Pershing LLC maintains assets that are held in all of the broker-dealer's customers’ accounts. In the case of a significant business disruption, the firm’s staff would be able to process clients' securities transactions through Pershing LLC's online platform or by calling its trading desk. The Firm’s employees can access the platform from any location worldwide via the use of their respective passwords and can alter profiles, check positions, accept inflows, request outflows, and execute orders via the platform from remote locations.
If a problem were to occur in the Firm’s office building (555 Madison Avenue, New York, NY 10022), the Firm’s staff would temporarily relocate to the uptown office of the Firm’s President, Thomas Kahn. This office is located in his residence in the Upper West Side of Manhattan. Clients can call that office at 212-315-5246 (KAHN) or contact the firm via email at accountservicse@kahnbrothers.com. In such an instance, each of the Firm’s employees would be notified by the Firm’s upper management either at his/her home or by cellular communication or email. The Firm’s principals have all employees' home and cellular phone numbers readily available. Once relocated, the Firm’s staff would be able to conduct business via Pershing’s platform, accessed over Mr. Kahn’s multiple broadband-connected computers or by telephoning Pershing LLC directly. Regulators would also be notified that the Firm would be reachable only at Mr. Kahn's uptown office.
Pershing LLC also maintains a business continuity plan that involves the maintenance of redundant data centers and alternate processing facilities to address interruptions to the normal course of business. Its plan outlines the actions that Pershing LLC would take in the event of a building, citywide or regional incident, including relocating technology and operational personnel to alternate regional facilities. Technology data processing can also be switched to their alternate regional data center, which can be accessed at Pershing LLC's website, www.pershing.com.
In the unlikely event that Kahn Brothers Group, Inc. and/or any of its subsidiary or affiliated companies cannot conduct business whatsoever, the Firm’s phone system answering message will advise clients to contact Pershing LLC directly to process limited trade-related transactions, cash disbursements and security transfers. Wire and transfer instructions to Pershing LLC must be in writing and signed and transmitted via facsimile or postal service to following address or fax number:
Pershing LLC
P.O. Box 2065
Jersey City, NJ 07303-2065
Fax: (201) 413-5368
For additional information on how to request funds and transact securities in the event of a significant business interruption, call (201) 413-3635 for recorded instructions. If you cannot access the instructions from this telephone number, Pershing LLC may be contacted at this alternate telephone number, (213) 624-6100 x500, which will also provide access to recorded instructions.
Kahn Brothers Group, Inc. and its subsidiary and affiliated companies execute their regulatory reporting over the internet. Therefore, in the event of a significant business interruption, the Firm can submit its Focus Report(s) from any computer that has internet access, including those in Mr. Kahn’s uptown office.
Kahn Brothers Group Inc.’s subsidiary broker-dealer, Kahn Brothers LLC, continuously monitors its financial risks and capital requirements. As an introducing firm that does not hold clients’ cash or securities, it has significantly more capital than required by the regulatory agencies. The broker-dealer monitors capital adequacy through consultations with its CPA and bookkeeper and through the filing of quarterly Focus Reports with the New York Stock Exchange that is, in turn, transmitted to the United States Securities and Exchange Commission. Firm policy prohibits underwriting securities, making markets in securities or purchasing securities with the Firm’s regulatory capital. Pershing LLC handles all receipts and deliveries of cash and securities from the Firm’s client accounts. The Firm has the policy of maintaining money market accounts only with reputable financial institutions such as JP Morgan Chase & Co. and the Dreyfus Corporation, a subsidiary of The Bank of New York Mellon Corp. By carefully selecting counter parties of substantial financial quality, the Firm is able to minimize exposure for itself and its clients in the event of major disruptions.
Kahn Brothers full Business Continuity Plan and latest quarterly Best Execution Report are available upon request.