Business Resiliency Plan

Purpose

E*TRADE Financial is committed to providing our customers with a high level of service and secure and reliable access to their accounts. Our business resiliency plans are designed to help ensure that we are able to continue to provide service to you, provide you with secure access to your assets and continue our business operations and that you will be able to reach us with minimal disruption regardless of any unplanned business interruption.

Recovery strategies and plans

E*TRADE Financial has taken comprehensive steps to provide for business resiliency planning under a variety of potential scenarios. We have recovery teams in place at each of our office locations to address the immediate response to an event and manage the situation from the time the event occurs until it is resolved. Our business resiliency plans are tested and evaluated on an ongoing basis to ensure we have the appropriate plans in place and resources to support the plans. Examples of the various scenarios our plans address include:

  • Data center or technology disruption

    E*TRADE Financial has plans in place to address the recovery of the Company’s technology and data. Our primary and alternate data centers are geographically separated on different power grids and supported by backup generators. This design helps ensure that if one of our locations suffers a disruption in service, systems at an alternate location can be used to continue to provide service.

  • Single building or regional disruption

    E*TRADE Financial has geographically dispersed office locations that support our customers and business operations. During a business disrupting event to a building, a business district, city, or region where we conduct business, we can rely on the systems and personnel in the other location(s) to allow us and our customers to continue to conduct business with minimal interruption. Our planning strategies also include relocating key personnel to and from the impacted location to designated alternate locations, as well as working remotely.

  • Third Party disruption

    E*TRADE Financial has plans in place to address third party service disruptions. In addition, a review of critical third parties’ business resiliency planning efforts is performed prior to contracting as well as on an ongoing basis.

  • Pandemic or workforce reduction

    E*TRADE Financial has plans in place to continue business during a reduction in our workforce, including a pandemic event. Our plan is a multi-tiered action plan based on the World Health Organization (WHO), Centers for Disease Control and Prevention (CDC), and Federal Government Response phases with triggering actions for each phase. As the threat of a pandemic becomes greater and a new phase is triggered, we will use our plans and determine the appropriate course of action.

Access to your accounts

Although E*TRADE Financial works hard to ensure that customers will continue to have access to their accounts in the event of a business disruption, it is possible that there may be some temporary disruption or change in the manner in which you can access your account. E*TRADE Financial will notify customers of any such changes or disruptions by posting a notice on the firm's web site, on social media, by email, or through a message on its telephone system.

To best prepare for such contingencies, we suggest that you become familiar with the various means through which you can access your account and place trades, including:

Although E*TRADE Financial has taken comprehensive steps to provide for business resiliency, no business resiliency plan can eliminate all risk or delay resulting from an unplanned business interruption or disruption in service. The success of our business resiliency plans includes dependencies on the locations we have identified as "pre-designated alternative sites" being available, that we have sufficient personnel, and that external organizations, such as government agencies, our nation's critical infrastructure and market systems, are operational. If any of these dependencies fails to recover in a timely manner, our business could be disrupted until matters are resolved. In the unlikely event that E*TRADE Financial has determined that it cannot resume operations within a reasonable amount of time, E*TRADE Financial will provide as much advance notice as possible regarding its ongoing operations.

E*TRADE Financial conducts regular assessments and updates and tests our plans to ensure we have taken the steps necessary to protect our customers. Updates to our plans will be reflected in this statement at least annually.