Last Updated: May 2025
Public Disclosure Summary

OpenYield Business Continuity & Pandemic Preparedness

1 Purpose

OpenYield maintains a written Business Continuity & Pandemic Preparedness Plan (“BCP”) that outlines how the firm will safeguard staff, protect data, and continue or promptly resume critical trading-platform operations after any Significant Business Disruption (SBD). The BCP is designed to satisfy FINRA Rule 4370 requirements and is reviewed, tested and re-approved at least annually.

2 Scope & Objectives

The plan applies to all business lines, technology systems, facilities, employees, and key third-party providers. Principal objectives are to:

Ensure personnel safety and life preservation.
Maintain operational and financial resiliency of the fixed-income Alternative Trading System (ATS).
Protect books, records and sensitive data from loss or unauthorized access.
Sustain continuous compliance with SEC, FINRA, and MSRB rules.

3 Governance & Responsibilities

Oversight rests with senior management. Specific officers (e.g., Chief Executive, Chief Technology, Chief Compliance, Operations, and Financial/FinOp functions) are assigned responsibility to maintain, test, approve, and activate the plan, as well as to keep regulator contact information current.

4 Risk Scenarios & Response Strategies

Disruption Type	Response Highlights
Internal SBD (e.g., office fire, local power outage)	Employees move to secure remote work; trading platform accessed via cloud; critical data retrieved from backups. Significant SBD’s are communicated to regulators and market participants.
External SBD – City/Region	Staff work remotely; alternative communications (phone, email, Slack, website) are in active use; regulators and market participants are updated.
Cloud / Data-Center Outage	ATS databases are restored to a designated cloud back-up instance with a recovery-time objective of the next trading day and a recovery-point objective of the prior trading day.
Widespread Health Emergency	Pandemic Manager activates health-safety protocols, remote work, and absentee monitoring; firm follows WHO/CDC guidance and keeps stakeholders informed through graded alerts (“Alert”, “Advisory”, “Update”).

5 Technology, Data Protection & Testing

Primary Hosting: ATS, order-matching, market-data and reporting systems are hosted in a secured Amazon Web Services (AWS) environment.
Data Back-ups: Google Drive and AWS snapshots preserve regulatory records (minimum seven-year retention) and corporate data (life of firm). Electronic communications are archived through Global Relay.
Annual Tests: Table-top simulations, cloud fail-over, database-restore drills and remote-access checks validate recovery procedures; results and remedial actions are documented.

6 Key External Relationships

OpenYield relies on:

Clearing & Settlement: A fully-disclosed clearing arrangement with RBC Capital Markets LLC which maintains its own BCP.
Cloud & Archiving Providers: Established vendors for hosting, backups and message archiving, each subject to annual BCP due-diligence reviews.
Banking Services: A regulated financial institution holds corporate funds; alternate banking arrangements are in place across multiple institutions.

7 Client Impact & Access to Funds

OpenYield does not hold customer funds or securities. In the unlikely event of a firm liquidation, a Securities Investor Protection Corporation (SIPC) trustee would transfer any customer positions in flight.

8 Ongoing Review & Public Availability

The BCP is updated after any material change and, at minimum, once per year. A copy of this disclosure summary is available on OpenYield’s public website and upon request. Detailed procedures remain confidential to protect security and regulatory integrity.

No part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, mechanical, electronic, photocopying, recording, or otherwise, without prior written permission of OpenYield, Inc. No licenses, express or implied, are granted with respect to any of the technology described in this document. OpenYield, Inc retains all intellectual property rights associated with the technology described in this document.

OPENYIELD INC MAKES NO WARRANTY OR REPRESENTATION, EITHER EXPRESS OR IMPLIED, WITH RESPECT TO THIS DOCUMENT, ITS QUALITY, ACCURACY, MERCHANTABILITY, OR FITNESS FOR A PARTICULAR PURPOSE. AS A RESULT, THIS DOCUMENT IS PROVIDED “AS IS,” AND YOU, THE READER, ARE ASSUMING THE ENTIRE RISK AS TO ITS QUALITY AND ACCURACY.

IN NO EVENT WILL OPENYIELD INC BE LIABLE FOR DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES RESULTING FROM ANY DEFECT, ERROR OR INACCURACY IN THIS DOCUMENT, even if advised of the possibility of such damages.

Some jurisdictions do not allow the exclusion of implied warranties or liability, so the above exclusion may not apply to you.