Cobra Trading Inc.
v.19.0
Last updated 4/3/2026
Table of Contents
- 1.0 – INTRODUCTION
- 1.1 – FIRM POLICY
- 1.2 – HOW TO USE THIS DOCUMENT
- 1.3 – DEFINITIONS
- BUSINESS CONTINUITY PLAN (BCP)
- SIGNIFICANT BUSINESS DISRUPTION (SBD)
- MISSION CRITICAL SYSTEMS
- 1.4 – DISTRIBUTION
- 1.5.1 – APPROVAL BCP AUTHORITY
- 1.5.2 – MAINTENANCE
- 1.5.3 – REVIEW OF THE PLAN
- 1.5.4 – TRAINING
- 2.0 – KEY BUSINESS INFORMATION & CRITICAL SYSTEMS
- 2.1 – BUSINESS DESCRIPTION
- 2.2 – CLEARING FIRM
- 2.3 – OFFICE LOCATIONS
- 2.4 – ALTERNATIVE PHYSICAL LOCATION(S) OF EMPLOYEES
- 2.5 – CUSTOMER ACCESS TO FUNDS AND SECURITIES
- 2.6 – DATA BACKUP AND RECOVERY (HARD COPY AND ELECTRONIC)
- 3.0 – FINANCIAL AND OPERATIONAL ASSESSMENTS
- 3.1 – OPERATIONAL RISK
- 3.2 – FINANCIAL AND CREDIT RISK
- 4.0 – MISSION CRITICAL SYSTEMS
- 4.1 – MISSION CRITICAL COMMUNICATION METHODS
- 4.2 – MISSION CRITICAL SYSTEMS
- 4.3 – FIRM’S MISSION CRITICAL SYSTEMS
- 4.3.1 – ORDER TAKING
- 4.3.2 – ORDER ENTRY
- 4.3.3 – ORDER EXECUTION
- 4.4 – MISSION CRITICAL SYSTEMS PROVIDED BY OUR CLEARING FIRM
- 5.0 – ALTERNATE COMMUNICATIONS BETWEEN THE FIRM, CUSTOMERS, EMPLOYEES & REGULATORS
- 5.1 – CUSTOMERS
- 5.2 – EMPLOYEES
- 5.3 – REGULATORS
- 6.0 – CRITICAL BUSINESS CONSTITUENTS, BANKS, AND COUNTER-PARTIES
- 6.1 – BUSINESS CONSTITUENTS
- 6.2 – BANKS
- 6.3 – COUNTER-PARTIES
- 7.0 – REGULATORY REPORTING
- 8.0 – DISCLOSURE OF BUSINESS CONTINUITY PLAN
- 9.0 – UPDATES AND ANNUAL REVIEW
- 10.0 – SBD EVENT PLAN
- 10.1 – COMMUNICATIONS WITH CUSTOMERS
- 10.1.1 – OUTBOUND COMMUNICATIONS
- 10.1.2 – INBOUND COMMUNICATIONS
- 10.2 – DATA SECURITY
- 10.3 – PHYSICAL SECURITY ACCESS
- 11.0 – SENIOR MANAGER APPROVAL
- EXHIBIT A — BUSINESS CONTINUITY MANAGEMENT TEAM (BCMT)
- EXHIBIT B — HOME OFFICE AND BRANCH LOCATIONS LIST / ALTERNATIVE LOCATION LIST
- EXHIBIT D — EMERGENCY CONTACT PERSONS
- EXHIBIT E — MISSION CRITICAL DOCUMENTS LIST
- EXHIBIT F — REGULATOR CONTACT INFORMATION
- EXHIBIT G — CLEARING FIRM CONTACT INFORMATION
- BCP CLIENT DISCLOSURE AND ACKNOWLEDGEMENT
- PURPOSE OF THIS DISCLOSURE
- FIRM POLICY
- FD
- DATA BACKUP
- PLAN REVIEW AND UPDATES
1.0 – Introduction
Planning for the business continuity of Cobra Trading, Inc. in the aftermath of a disaster is a complex task. Preparation for, response to, and recovery from a disaster affecting the administrative and operational functions of the Firm requires the cooperative efforts of different internal and external personnel. This document records the Plan that outlines and coordinates these efforts, reflecting the analyses by the Firm’s Business Continuity Management Team (BCMT) (See Exhibit A for list of BCMT personnel).
For use in the event of a disaster, this document identifies key operational and document control systems and key decisions that should be implemented in the case of a Significant Business Disruption (SBD).
1.1 – Firm Policy
Cobra Trading’s policy is to respond to a SBD by safeguarding employees’ health and safety and Firm property, making a financial operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and allowing its customers to transact business.
The Firm’s strategy is to manage an approved corporate-wide Business Continuity Program (BCP) to maintain the policy and standards while providing a comprehensive education and implementation process. The objective is to create, document, test and maintain departmental business continuity plans to recover critical systems and functions. At least annually, operations departments with critical business processes and technology departments test their plans to ensure that they are workable, in compliance and that staff are aware of their roles in a business interruption. A corporate communication and management process exists to ensure critical business functions resume quickly, thereby reducing financial risk.
The Firm provides in writing this BCP disclosure statement or an updated version to customers upon request. The Firm creates and documents BCP plans based on the potential risks of disruption to its employees, workspace and/or technology in its location.
1.2 – How To Use This Document
Use this document to learn about the issues involved in planning for the continuity of the critical and essential business functions at Cobra Trading, Inc. as a checklist of preparation tasks, for training personnel, and for recovering from a SBD.
1.3 – Definitions
Business Continuity Plan (BCP)
The primary objective of this Business Continuity Plan (BCP) is to enable the Firm to survive a disaster and to re-establish normal business operations. In order to survive, the Firm must assure that critical operations can resume normal processing within a reasonable time frame.
Significant Business Disruption (SBD)
The Firm’s business continuity plan covers three types of disruptions:
- Firm Disruptions (FD) — Includes but is not limited to firm disruptions such as building fires, a building power outages, computer or network malfunctions or virus infection disruptions or disconnections of telephone services.
- Local Disruptions (LD) — Includes but is not limited to local disruptions such as regional floods, fires, terrorist attacks, earthquakes, tornados, hurricanes, chemical spills or regional power, telephone or internet outages.
- Regional Disruptions (RD) — Includes but is not limited to regional disruptions such as power grid failures or regionally affected natural disasters or terrorist attacks.
Mission Critical Systems
For purposes of FINRA Rule 4370, FINRA defines “mission critical system” as “any system that is necessary, depending on the nature of a member’s business, to ensure prompt and accurate processing of securities transactions, including, but not limited to, order taking, order entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts and the delivery of funds and securities.”
For purposes of FINRA Rule 4370, FINRA defines “Financial and operational assessment” as a set of written procedures that allow a member to identify changes in its operational, financial, and credit risk exposures.
1.4 – Distribution
As the written record of the Firm’s Business Continuity Plan, this document is distributed to each member of the Business Continuity Management Team (BCMT). Additionally a copy of this plan will be located at each Office, OSJ, Non-OSJ and satellite branch locations listed in Exhibit B of this document. The firm’s BCP master document is located at the Firm’s headquarters. The Firm will make available this plan to FINRA Staff promptly upon request. An electronic copy of the plan is located on a designated computer located at the Firm’s headquarters and on a designated computer located at the alternative physical location (Exhibit B). In addition, each member of the BCMT (Exhibit A), has a hard copy version of this plan at his/her residence.
1.5 – Reviewing, Updating and Training
All updates are made with the recommendation and approval of the BCMT. As updates are approved, the President distributes updated copies of the BCP to each associate of the Firm.
1.5.1 – Approval BCP Authority
The President is responsible for the training, review and approval of the BCP. Should the President be unable to fulfill these duties, the Director of Operations will assume these responsibilities.
1.5.2 – Maintenance
The BCMT is responsible for ensuring any changes to the BCP are reflected in this document.
1.5.3 – Review of the Plan
The BCMT conducts periodic reviews of the BCP on a regular basis. Updates to the BCP are logged as noted on Exhibit C.
Quarterly, the BCMT reviews select components of the BCP and updates approved changes.
Annually, the BCMT conducts a review of the BCP which may result in revisions. If revised, the updated BCP is distributed to all authorized personnel.
1.5.4 – Training
Training on the BCP is conducted annually and is logged.
2.0 – Key Business Information & Critical Systems
2.1 – Business Description
Cobra Trading conducts business primarily in equity securities. The Firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, the Firm does not hold customer funds or securities. The Firm accepts and enters orders. All transactions are sent to the clearing firms. The clearing firms execute, compare, allocate, clear and settle the transactions. The clearing firms also maintain the Firm’s customers’ accounts, grant customers access to them and deliver funds and securities. Cobra Trading services both retail and institutional customers.
2.2 – Clearing Firm
Cobra Trading utilizes two clearing firms, Wedbush Securities, Curvature Securities LLC and Interactive Brokers LLC. Review Exhibit G for contact information.
2.3 – Office Locations
See Exhibit B for Cobra Trading’s office locations.
2.4 – Alternative Physical Location(s) of Employees
See Exhibit B for Cobra Trading’s alternative physical locations.
2.5 – Customer Access to Funds and Securities
Cobra Trading does not maintain custody of customers’ funds or securities. These are maintained at the clearing firms (Wedbush Securities, Curvature Securities LLC and Interactive Brokers LLC). In the event of an internal or external SBD, the Firm’s registered persons will take customer orders and/or instructions and contact our clearing firms on their behalf. If the Firm’s website is available, customers can access their funds and securities by contacting the clearing firms directly. Cobra Trading will provide alternate phone numbers and will make the clearing firms’ contact information available to customers as required.
If SIPC determines that the Firm is unable to meet its obligations to customers or if its liabilities exceed its assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse the Firm’s assets to customers. Cobra Trading will assist SIPC and the trustee by providing its books and records identifying customer accounts subject to SIPC regulation and oversight.
2.6 – Data Backup and Recovery (Hard Copy and Electronic)
Cobra Trading maintains its primary hardcopy books and records and its electronic records at its main office identified in Exhibit B. Chadd Hessing is responsible for the maintenance of these books and records. See Exhibit E for firm’s mission critical documents and forms.
In the event of an internal or external SBD that causes the loss of its mission critical documents, Cobra Trading will either physically recover the storage media or electronically recover data from its backup site. If the Firm’s primary site is inoperable, it will continue operations from its backup site or an alternate location.
3.0 – Financial and Operational Assessments
3.1 – Operational Risk
In the event of a SBD, Cobra Trading will immediately identify what means will permit it to communicate with its customers, employees, critical business constituents, critical banks, critical counter-parties, and regulators. The Firm will use its telephone, voice mail, cell-phone, e-mail, etc. In addition, the Firm will retrieve its business records as described in the section 2.6. (Data Backup and Recovery)
3.2 – Financial and Credit Risk
In the event of an SBD, Cobra Trading will determine the value and liquidity of its investments and other assets to evaluate its ability to continue to fund its operations and remain in capital compliance. The Firm will contact its critical banks and existing clients to apprise them of the Firm’s financial status. If the Firm determines that it may be unable to meet its obligations to existing clients or otherwise continue to fund its operations, it will request additional financing from its bank or other credit sources to fulfill its obligations to customers and clients. If the Firm cannot remedy a capital deficiency, it will file appropriate notices with its regulators and immediately take appropriate steps.
4.0 – Mission Critical Systems
Cobra Trading’s “mission critical systems” are those that ensure prompt communication with its clients and their representatives.
4.1 – Mission Critical Communication Methods
The following are Cobra Trading’s mission critical communication methods:
- Telephone
- Fax
- The ability to access the internet
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.
4.2 – Mission Critical Systems
Cobra Trading’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions. These include:
- Order acceptance
- Entry and execution
- Comparison
- Allocation
- Clearance and settlement of securities transactions
- Maintenance of customer accounts
- Access to customer accounts
- Delivery of funds and securities
Cobra Trading is primarily responsible for order acceptance, entry and execution.
The clearing firms are primarily responsible for the execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities.
The clearing firms will maintain their own BCPs. Any material changes to their BCPs that might affect Cobra Trading’s ability to maintain its business will be communicated to Cobra Trading. Should the clearing firms be unable to fulfill their obligations while experiencing an SBD, they will assist Cobra Trading in seeking alternative clearing services.
The clearing firms back up Cobra Trading’s information at geographically alternative backup sites.
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.
4.3 – Firm’s Mission Critical Systems
4.3.1 – Order Acceptance
Currently, Cobra Trading receives customer orders via third party trading platforms or by phone. During SBDs, the Firm will continue to accept orders through any of these methods that are available and reliable, and in addition, as communications permit, the Firm will inform its customers when communications become available to inform them what alternatives they have to submit their orders to the Firm. If necessary, the Firm will instruct customers to submit orders directly through its clearing firms, Wedbush Securities, Curvature Securities or Interactive Brokers, LLC.
4.3.2 – Order Entry
Cobra Trading enters orders electronically and sends them to its clearing firms electronically or by phone. The Firm places customer orders through DAS, RealTick, Sterling, and Trader Workstation.
In the event of an internal SBD, the Firm will enter and send records to its clearing firms by the fastest alternative means available, which include telephone and email. In the event of an external SBD, the Firm will maintain orders in electronic or paper format, and deliver orders to the clearing firms by the fastest means available once it resumes operations. In addition, during an internal SBD, the Firm may need to refer our customers directly to the clearing firms for order entry.
4.3.3 – Order Execution
Cobra Trading currently executes orders via third party trading platforms. In the event of an internal SBD, the Firm would phone orders directly to the clearing firms using cell phones. In the event of an external SBD, the Firm would continue to execute orders through our service bureaus.
4.4 – Mission Critical Systems Provided by Clearing Firms
Cobra Trading relies, by contract, on its clearing firms to provide order execution, order comparison, order allocation, and the maintenance of customer accounts, delivery of funds and securities, and access to customer accounts.
5.0 – Alternate Communications Between the Firm, Customers, Employees & Regulators
5.1 – Customers
Cobra Trading communicates with its customers using the telephone, e-mail, fax, and U.S. mail. In the event of an SBD, the Firm will assess which means of communication are available to it, and use the means closest in speed and form (written or oral) to the means that it has used in the past to communicate with the other party. For example, if the Firm has communicated with a party by e-mail but the Internet is unavailable, the Firm will call them on the telephone and follow up where a record is needed with paper copy through the U.S. mail.
5.2 – Employees
Cobra Trading communicates with its employees via telephone, e-mail, and in person. In the event of an SBD, the Firm will assess which means of communication are available to it, and use the means closest in speed and form (written or oral) to the means that it has used in the past to communicate with the other party. The Firm will also employ a call tree so that senior management can reach all employees quickly during an SBD. The call tree includes all staff home and office phone numbers. The Firm has identified persons, noted below, who live near each other and may reach each other in person:
The person to invoke use of the call tree is: Chadd Hessing
| Caller | Call Recipients |
|---|---|
| Chadd Hessing Office: (972) 491-7999 Cell: 469-469-4247 | Thomas Terry — Cell: 469-469-4245 David Longobardi — Cell: 469-669-5687 |
5.3 – Regulators
Cobra Trading is currently a member of the following SROs:
- FINRA – Financial Industry Regulatory Authority
- NFA – National Futures Association
The Firm communicates with its regulators via telephone, e-mail, fax, U.S. mail, and in person. In the event of an SBD, the Firm will assess which means of communication are available to it, and use the means closest in speed and form (written or oral) to the means that it has used in the past to communicate with the other party.
6.0 – Critical Business Constituents, Banks, and Counter-Parties
6.1 – Business Constituents
Cobra Trading may need to rely upon the recovery and restoration of services provided by various critical business constituents. Cobra Trading has considered the extent to which the Firm may be able to depend upon these business relationships during a SBD as part of its decision to do business with the constituents. Where possible, the Firm has engaged and/or vetted alternate arrangements in order to avoid business disruptions in the case of a business constituent not being able to provide needed goods or services in an emergency.
Internet:
Frontier Communications
2221 Lakeside Blvd.
Richardson, TX 75082
1-877-600-1511 / 1-800-921-8101
www.frontier.com
NetFortris
5340 S. Legacy Dr., Suite 155
Plano, TX 75024
877-366-2548
www.netfortris.com
Telephone:
NetFortris
5340 S. Legacy Dr., Suite 155
Plano, TX 75024
877-366-2548
www.netfortris.com
WebHost:
Amazon Web Services
aws.amazon.com
Connectivity setup and established through Advantix Digital
Web Design Company:
Advantix Digital
14285 Midway Rd., Suite 475
Addison, TX 75001
https://avxdigital.com
6.2 – Banks
Cobra Trading has contacted its banks and lenders to evaluate whether they can continue to provide the financing needed in light of the internal or external SBD. The Firm’s bank is:
Chase Bank
Business Banking
Sean Brew – Relationship Manager
8111 Preston Rd., Floor 2
Dallas, TX 75225
214-360-3918
www.chase.com
6.3 – Counter-Parties
The clearing firms which maintain our Proprietary Accounts of Introducing Brokers/Dealers (PAIB accounts) are:
Wedbush Securities, Inc
1000 Wilshire Blvd.
Los Angeles, CA 90017
www.wedbush.com
Interactive Brokers LLC
One Pickwick Plaza, 2nd Floor
Greenwich, CT 06830
www.interactivebrokers.com
Curvature Securities, LLC
39 Main Street
Chatham, NJ 07928
https://curvaturesecurities.com/
7.0 – Regulatory Reporting
Cobra Trading is subject to regulation by: SEC, FINRA, NFA and various state securities Departments. The Firm files reports either in hardcopy format via U.S. mail or electronically via fax, e-mail, or Internet. In the event of an SBD, the Firm will determine which means of filing are available to it, and use the means closest in speed and form (written or oral) to its previous filing method. In the event that the Firm is unable to contact its regulators, it will continue to file required reports using the communication means available to it. See Exhibit F for Regulator contact information.
8.0 – Disclosure of Business Continuity Plan
Cobra Trading discloses in writing a summary of its BCP to customers at account opening. The Firm also posts a plan summary on its website and mails a copy to customers upon request. The plan summary addresses the possibility of a SBD and how the Firm plans to respond to events of varying scope.
9.0 – Updates and Annual Review
Cobra Trading updates the BCP as needed. Any material changes to the Firm’s operations, structure, business or location will result in updates to the plan. The BCP is reviewed at least annually.
10.0 – SBD Event Plan
In the event of a SBD the following plan will be followed:
If a Significant Business Disruption event causes the evacuation of its facility at 3008 E. Hebron Pkwy, Bldg 400, Carrollton, TX, Chadd Hessing will activate the business continuity plan. Cobra Trading staff and associates will relocate to an alternate location: 2480 Raintree Dr., Southlake, TX 76092
- The Business Continuity Management Team (BCMT) will contact current clients, regulators, banks, and business constituents via e-mail, telephone or fax. The BCMT will relay important information regarding the current state of business operations.
- Cobra Trading’s BCMT will ensure the BCP is implemented.
10.1 – Communications with Customers
10.1.1 – Outbound Communications
Cobra Trading’s BCMT will contact customers with information and/or instructions.
10.1.2 – Inbound Communications
Customers are expected to contact Cobra Trading using current communication avenues.
If the existing communication avenues are unavailable, customers are expected to follow the contact instructions listed in the SBD Client Disclosure Form.
10.2 – Data Security
Cobra Trading contracts with its third-party technology provider to store and backup copies daily of all relevant access data and programs. Should access files or programs be destroyed or corrupted due to a SBD, they would be quickly restored in accordance with Securities and Exchange Commission regulations.
10.3 – Physical Security Access
If there is a security system failure at Cobra Trading’s facilities due to an event, the Firm will implement the following guidelines:
- Cobra Trading associates and authorized vendor support personnel only will have access to the premises. All access will be monitored.
- Any access required by associates, vendors, and consultants will be approved by senior management.
- Vendors required to make repairs to the facility will be required to have a Cobra Trading associate present on the premises.
11.0 – Senior Manager Approval
I have approved this Business Continuity Plan as reasonably designed to enable Cobra Trading firm to meet its obligations to customers in the event of an SBD.
Signed: ___________________
Title: ___________________
Date: ___________________
Exhibit A — Business Continuity Management Team (BCMT)
| Name | Title with the Firm | Location | Phone | Date of BCMT Membership |
|---|---|---|---|---|
| Chadd Hessing | CEO | Main Office | (972) 491-7999 | 10/10/2004 |
| Thomas Terry | Chief Operating Officer | Main Office | TT@cobratrading.com / Tomttu@gmail.com |
Exhibit B — Home Office and Branch Locations List
| Location Address | Phone Number | Branch Manager | OSJ, Non-OSJ, or Satellite Office | Orders Taken at this location (Yes/No) | Transport Method |
|---|---|---|---|---|---|
| 3008 E. Hebron Pkwy, Bldg 400, Carrollton, TX | (972) 491-7999 | N/A | OSJ | Yes | Car, Bus |
Alternative Location List
| Location Address | Phone Number | Fax Number |
|---|---|---|
| 2480 Raintree Dr., Southlake, TX 76092 | (469) 469-4247 | (972) 491-3111 |
Exhibit C — Plan Review and Results
| Date | Plan Reviewed | Results of Review | BCMT Signatory |
|---|---|---|---|
| 1/25/05 | Version 1.0 | Removed Chad Thompson from BCMT. | CH |
| 10/1/05 | Version 1.0 | Changed main facility address to 431 Second Street, Suite 302, Hudson, WI 54016. | CH |
| 5/1/05 | Version 1.0 | Added employee Lonnie Vogt to the BCP section 5.2. | CH |
| 1/25/06 | Version 2.0 | Test contacts in 6.1 to verify information. | CH |
| 5/1/06 | Version 2.0 | Added employee Keith Kleinschmidt to the BCP section 5.2. | CH |
| 1/25/07 | Version 3.0 | Reviewed Penson Financial Services BCP for suitability with Cobra’s BCP. | CH |
| 10/1/07 | Version 3.0 | Changed and tested alternative location address and phone number. | CH |
| 12/15/07 | Version 3.0 | Added employees Megan Hiekel and Brandon Kaisler to the BCP section 5.2 and removed employee Keith Kleinschmidt from the BCP section 5.2. | CH |
| 1/25/08 | Version 4.0 | Test 2.6 Data Backup and Recovery to electronically and physically recover data. | CH |
| 4/23/09 | Version 5.0 | Added employee Paul McIntosh to the BCP Section 5.2 and removed employees Lonnie Vogt and Megan Hiekel from the BCP Section 5.2. | CH |
| 5/6/09 | Version 6.0 | Added telephone provider Preferred Long Distance to BCP Section 6.1. Changed BCP Exhibit G, removing Frank Hess and replacing with Ryan Dill. | CH |
| 03/11/2010 | Version 7.0 | Made changes to firm address, phone number and alternative physical location. Changed FINRA District Office. Added Brandon Kaisler to BCM. Other significant material updates to the Plan. | CH |
| 03/31/2010 | Version 8.0 | Added Eric Wilkinson to BCP Plan | CH |
| 10/26/2011 | Version 9.0 | Added Interactive Brokers, LLC to BCP Plan. Removed Eric Wilkerson, Jennifer Warrick. Added Dan Miner, Kyle Shipley. Changed Alt Contact from David McBride to Brandon Kaisler. | CH |
| 09/13/2012 | Version 10.0 | Added Wedbush Securities to Business Continuity Plan. | CH |
| 04/22/2014 | Version 11.0 | Updated clearing firm information and certain contact information. Updated Order Entry information. | CH |
| 12/18/2014 | Version 11.0 | Removed Penson Financial Services, added NFA, updated physical address for business, updated physical address for backup location, updated phone numbers, internet providers, removed Kyle Shipley, and added Jeremy Harper | CH |
| 3/26/2015 | Version 12.0 | Updated clearing firm executive BCP summary, updated banking detail, and added Michelle Solt | |
| 4/2/2016 | Version 13.0 | ||
| 10/2/2017 | Version 14.0 | Updated clearing firm information and certain grammatical errors | CH |
| 7/12/2019 | Version 15.0 | Updated IB contact information | CH |
| 4/1/2020 | Version 16.0 | Updated IB contact information, updated platforms, Grammatical changes, Updated call recipients, updated alternative location, updated data security, updated regulator contact info, updated Brandon Kaisler CCO | CH |
| 9/1/2020 | Version 17.0 | Update of Firms primary business address | CH |
| 4/23/2023 | Version 18.0 | Update COO information and add Curvature as clearing firm. | CH |
| 4/20/2026 | Version 19.0 | Updated CEO and COO’s phone numbers | CH |
Exhibit D — Emergency Contact Persons
Below are the emergency contacts for Cobra Trading, Inc.
| Contact Name | Phone | Alternate Phone | Alternative E-mail | |
|---|---|---|---|---|
| Chadd Hessing | 469-469-4247 | – | ch@cobratrading.com | chaddhessing@hotmail.com |
| Thomas Terry | 469-469-4245 | – | TT@cobratrading.com | Tomttu@gmail.com |
The above names will be updated as changes occur. The Firm’s CCO will review this list within 17 business days following the end of each fiscal year via the FINRA Contact System located through the FINRA Gateway System.
Exhibit E — Mission Critical Documents List
Operational:
- Risk disclosures
- Daily trade blotter
- Affirmative determination log
- Cash and Securities Received and Forwarded Blotters
Regulatory:
- Financial Statements
- Net Capital Computations
Exhibit F — Regulator Contact Information
FINRA District 6
12801 North Central Expressway, Suite 1050
Dallas, TX 75243-1778
(972) 701-8554
Fax: (972) 716-7646
Mara London
Principal Analyst – Risk Monitoring
FINRA
200 Liberty Street
NY, NY 10281
T. 646-315-7373
State Regulators
Texas (State of Domicile)
Physical Address:
Texas State Securities Board
208 East 10th Street, 5th Floor (Rusk Building)
Austin, Texas 78701
512-305-8300
| State | Phone |
|---|---|
| Alabama | 334-242-2984 |
| Alaska | 334-242-2984 |
| Arizona | 602-542-4242 |
| Arkansas | 501-324-9260 |
| California | 916-445-7205 |
| Colorado | 303-894-2320 |
| Connecticut | 860-240-8230 |
| Delaware | 302-577-8424 |
| Florida | 850-410-9805 |
| Georgia | 404-656-3920 |
| Hawaii | 808-586-2744 |
| Idaho | 208-332-8004 |
| Illinois | 312-793-3384 |
| Indiana | 317-232-6681 |
| Iowa | 515-281-4441 |
| Kansas | 785-296-3307 |
| Kentucky | 502-573-3390 |
| Louisiana | 225-925-4512 |
| Maine | 207-624-8551 |
| Maryland | 410-576-6360 |
| Massachusetts | 617-727-3548 |
| Michigan | 877-999-6442 |
| Minnesota | 651-296-4026 |
| Mississippi | 601-359-6371 |
| Missouri | 573-751-4136 |
| Montana | 406-444-2040 |
| Nebraska | 402-471-3445 |
| Nevada | 702-486-2440 |
| New Hampshire | 603-271-1463 |
| New Jersey | 973-504-3600 |
| New Mexico | 505-476-4580 |
| New York | 212-416-8222 |
| North Carolina | 919-733-3924 |
| North Dakota | 701-328-2910 |
| Ohio | 614-644-7381 |
| Oklahoma | 405-280-7700 |
| Oregon | 503-378-4387 |
| Pennsylvania | 717-787-8061 |
| Puerto Rico | 787-723-3131 ext. 2222 |
| Rhode Island | 401-222-3048 |
| South Carolina | 803-734-4731 |
| South Dakota | 605-773-4823 |
| Tennessee | 615-741-2947 |
| Texas | 512-305-8300 |
| Utah | 801-530-6600 |
| Vermont | 802-828-3420 |
| Virginia | 804-371-9051 |
| Washington | 360-902-8760 |
| Washington DC | 202-727-8000 |
| West Virginia | 304-558-2257 |
| Wisconsin | 608-261-9555 |
| Wyoming | 307-777-7370 |
Exhibit G — Clearing Firm Contact Information
Main Contact Information
| Name | Address | Phone | Website | |
|---|---|---|---|---|
| Wedbush Securities / Edna Palacios | 1000 Wilshire Blvd., Los Angeles, CA 90017 | (213) 688-4324 | edna.palacios@wedbush.com | www.wedbush.com |
| Interactive Brokers LLC / Allison Tenerelli | One Pickwick Plaza, 2nd Floor, Greenwich, CT 06830 | (312) 542-6860 | atenerelli@interactivebrokers.com | http://interactivebrokers.com/ |
| Curvature Securities LLC / Scott Bauer | 39 Main Street, Chatham, NJ 07928 | (908) 741-4120 | sbauer@curvaturesecurities.com | https://curvaturesecurities.com/ |
Alternative Contact Information
| Name | Address | Phone | Website | |
|---|---|---|---|---|
| Wedbush Securities / Operations | 1000 Wilshire Blvd., Los Angeles, CA 90017 | 213-688-6600 | technicaloperations@wedbush.com | www.wedbush.com |
BCP Client Disclosure and Acknowledgement
Date: 04/20/2026
Subject: Business Continuity Plans
FINRA Rule 4370
Effective Date: 04/20/2026
Purpose of this Disclosure
FINRA Rule 4370 requires member firms to create and maintain a written business continuity and contingency plan and procedures relating to an emergency or Significant Business Disruption (“SBD”)
Firm Policy
Cobra Trading’s policy is to respond to a SBD by safeguarding employees’ health and safety and Firm property, making a financial operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and allowing its customers to transact business.
The Firm’s strategy is to manage an approved corporate-wide Business Continuity Program (BCP) to maintain the policy and standards while providing a comprehensive education and implementation process. The objective is to create, document, test and maintain departmental business continuity plans to recover critical systems and functions. At least annually, Operations departments with critical business processes and Technology departments test their plans to ensure that they are workable, in compliance and that staff are aware of their roles in a business interruption. A corporate communication and management process exists to ensure critical business functions resume quickly, thereby reducing financial risk.
Cobra Trading provides in writing this BCP disclosure statement or an updated version to customers upon request. The Firm creates and documents BCP plans based on the potential risks of disruption to its employees, workspace and/or technology in its location.
Significant Business Disruption (SBD)
Definitions:
The Firm’s BCP covers three types of disruptions:
- Firm Disruptions (FD) — Includes but are not limited to firm disruptions such as a building fire, a building power outage, computer or network malfunction or virus infection disruption or failure of telephone services.
- Local Disruptions (LD) — Includes but not limited to local disruptions such as regional floods, fires, terrorist attacks, earthquakes, tornados, hurricanes, chemical spills or regional power, telephone or internet outages.
- Regional Disruptions (RD) — Includes but not limited to regional disruptions such as power grid failures or regionally affected natural disasters or terrorist attacks.
FD
In the event of a FD, clients can call the Firm’s alternative location at 469-469-4247 for information and instructions. Cobra Trading is expected to be operational within a period of two hours of the FD.
LD
In the event of a LD, clients can call the Firm’s alternative location at 469-469-4247 or if the secondary location is affected by the LD, clients can call the clearing firms, Wedbush Securities (for Cobra Trading) at (213) 688-4324, Curvature Securities LLC (908) 741-4120 or Interactive Brokers (for Venom Trading) at (312) 542-6846 for information and instructions. Under this scenario, Cobra Trading will close operations and inform its clients via phone, e-mail or website of its expected recovery time.
RD
In the event of a RD, clients can call the Firm’s alternative location at 469-469-4247 or if the secondary location is affected by the RD, clients can call the clearing firms, Wedbush Securities (for Cobra Trading) at (213) 688-4324, Curvature Securities LLC (908) 741-4120 or Interactive Brokers (for Venom Trading) at 312.542.6846 for information and instructions.
Data Backup
Cobra Trading maintains its primary copy of books and records at its main office located at 3008 E Hebron Pkwy, Bldg 400, Carrollton, TX. The Firm maintains backup copies at its alternate location: 2480 Raintree Dr., Southlake, TX 76092.
Plan Review and Updates
This Business Continuity Plan is subject to change and is modified and tested at least annually for updates and revisions. An updated and current copy of this summary is posted and can be viewed at http://www.cobratrading.com Clients can also request this document by calling the firm and a copy will be mailed via U.S mail.