Aileron Capital Management, LLC is a fund management firm and FINRA registered broker dealer. The company specializes in lending and financing programs sponsored by the U.S. Government, and is licensed by the Small Business Adminstration as a secondary market pool assembler for SBA guaranteed loans.
Business Continuity Plan Disclosure
Aileron Capital Management, LLC ("Aileron") has developed a Business Continuity Plan in order to respond to events that significantly disrupt our business subject to prudent business practices and FINRA rule 4370 requirements. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
I. Emergency Contact Persons
Aileron has designated the following persons as the emergency contact persons:
• Robert Beard (813) 341-3654 x101 and firstname.lastname@example.org
• Michael Maguire (813) 341.3654 136 and email@example.com
These names will be updated in the event of a material change, and will be reviewed on an annual basis as described in the Firm’s Written Supervisory Procedures.
II. Firm Policy
Aileron’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. Because the Firm shall not accept funds, establish accounts, or perform any activities for outside customers, these policies and procedures do not include any related to the restoration and continued access of customers.
A. Significant Business Disruptions (SBDs)
Aileron’s plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the Firm’s ability to communicate and do business, such as a fire in its 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. The response to an external SBD relies heavily on other organizations and systems.
B. Approval and Execution Authority
Michael Maguire, CEO, a registered principal, is responsible for approving the plan and for conducting the required annual review. Both Robert Beard, CFO and Managing Director, and Michael Maguire, have the authority to execute this BCP.
C. Plan Location and Access
Aileron will maintain copies of its BCP plan, the annual reviews and the changes that have been made to it for inspection. An electronic copy of the plan is located on the S Drive at Aileron Capital Management / Common Files / Disaster Recovery Plan.
III. Business Description
Aileron is a broker/dealer whose sole regulated investment related activity is being a dealer in the purchase and resale of first mortgage commercial loans via the U.S. Small Business Administration (“SBA”) 504 First Mortgage Loan Pool program. The Firm sells the SBA Certificates by distributing bid sheets of its SBA eligible pooled loans solely to full service broker/dealers seeking to purchase the SBA Investment Certificates for their own investments or trading accounts. Furthermore, Aileron does not maintain accounts for customers or hold customer funds or securities.
For More Information
If you have questions about our business continuity planning, you can contact us at Aileron Capital Management, LLC, 2111 W. Swann Ave., Suite 200, Tampa, FL 33606, (813) 341-3654. If you would like to receive a copy of our plan, please send a written request to Aileron Capital Management, LLC, Compliance Dept., 2111 W. Swann Ave., Suite 200, Tampa, FL 33606.