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FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTS DR VIINovember 2010 Compiled and Developed by Tellefsen and Company, L.L.C.

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Page 1: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

FUTURES INDUSTRY BUSINESS CONTINUITY

AND DISASTER RECOVERY

2010 INDUSTRY TEST RESULTS“DR VII”

November 2010Compiled and Developed by

Tellefsen and Company, L.L.C.

Page 2: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

I. Background 3

II. Executive Summary 7

III. Overall Test Results 10

IV. Problems Encountered 24

V. Lessons Learned 27

VI. Suggested Next Steps 31

TABLE OF CONTENTS

Page Number:

Page 3: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

The FIA Information Technology Division conducted the first annual Disaster Recovery (DR) Test in October 2004.Starting in Q1, 2010, the FIA Business Continuity Committee began detailed preparations for this year’s seventh annual industry-wide test.A Working Group was convened to discuss and agree on a date, goals, objectives, etc.

I. BACKGROUND

Page 4: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Two futures Industry BC/DR symposiums were held in June and September in New York and Chicago. Panelists included representatives from the major exchanges and clearinghouses:

CBOE Futures ExchangeChicago Climate Futures ExchangeCME Group (CBOT, CME, NYMEX, COMEX)CME ClearingELX FuturesICE ExchangesICE Futures USICE Clear USICE Clear EUInternational Derivatives Clearing GroupKansas City Board of TradeKCBT Clearing Corp.MEFFMinneapolis Grain ExchangeBourse de MontrealOptions Clearing Corp.

BACKGROUND (Cont’d) …

Page 5: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

The scope of this year’s initiative was designed to test disaster recovery back-up connectivity and functionality between exchanges, clearinghouses and member firms:– Test firm back-up to exchange back-up sites (DR-DR).– Verify connectivity.– Test round-trip communications capabilities.

The symposium sessions were well attended by numerous operations managers and BC/DR representatives from various clearing and non-clearing firms.

Regular Committee conference calls were held between May and October (bi-weekly and weekly).

BACKGROUND (CONT’D) …

Page 6: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

The Committee including representatives from:– Clearinghouses– Exchanges– FCMs– Clearing firms– Non-clearing firms– Key service providers– Independent software vendors

Post-test interviews with firms and survey forms were used to fine tune the results.

BACKGROUND (Cont’d) …

Page 7: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

The seventh annual industry-wide disaster recovery test in the U.S. financial services sector was highly successful, largely in part to the good working relationship between exchanges and the firms.

Major U.S. and international futures exchanges, clearinghouses, FCMs and clearing firms participated in this year’s test:

73 FCMs, clearing firms and non-clearing firms and 38 trading participants participated - an increase over last year~72% of firms tested successfully

II. EXECUTIVE SUMMARY

Page 8: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

This year’s test initiative was expanded to include several domestic and international exchanges:

Bourse de MontrealChicago Climate Futures ExchangeELX Futures

The exchanges and clearinghouses demonstrated that their systems, processes and procedures simultaneously worked very well, communicating from back up systems/sites.

EXECUTIVE SUMMARY (CONT’D) …

Page 9: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Feedback from the firms, exchanges and clearing houses indicated that this was a valuable and worthwhile exercise and that the industry should continue to do more common testing in the future

Firms indicated that the test helped them:– Exercise their business continuity/disaster recovery plans– Identify internal single points of failure– Tighten up and document their business continuity

procedures– Better understand the need for cross-training– Test connectivity with exchanges’ DR sites

EXECUTIVE SUMMARY (CONT’D) …

Page 10: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

13 domestic and international futures exchanges and clearinghouses, 73 clearing/non-clearing firms* and 38 trading firms participated** in the test

Test participants included clearing firms, non-clearing firms and non-clearing trading participants

61% of all futures clearing firms participated

Participant firms represent a significant critical mass of futures order flow and liquidity:

~88% of overall futures exchanges’ volume.

* Some firms are common members of multiple exchanges** Represents non-clearing trading participants

III. OVERALL TEST RESULTS

Page 11: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested via member firms’ back up connectivity to back up CBOEdirect trading platform

Scripted trade entry for VIX futures contracts

Transmitted trades to the OCC’s back up systems via MQ

Transmitted regulatory data to NFA via FTP.

CBOE FUTURES EXCHANGE

Page 12: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested via member firms’ back up connectivity to CCFE electronic trading system DR site hosted by ICE

Scripted trade entry occurred for RGGI and SFI futures contracts and block trades

Tested the availability and operability of the exchange’s market surveillance applications, hosted out of the DR site

Tested connectivity and trade submission to the Clearing Corp’s DR site.

CHICAGO CLIMATE FUTURES EXCHANGE

Page 13: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested member firms back-up connectivity to GLOBEX trading platformEntered a script of orders for various productsReceived ex-pit, block trade information via CME remote site portal URLGenerated trade reporting and SPAN files from 10/22 trade dateReceived PCS and large trader information from member firmsTransmitted trade registry data and SPAN files via FTP.

CME GROUP / CME CLEARING

Page 14: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested via eSpeed electronic trading system

Trade date was Monday October 25th

Trading products included all ELX UST and Eurodollar futures contracts via eSpeed supported API’s

Block trades or EFP trade types were not accepted.

ELX FUTURES

Page 15: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Utilized the IDEX XT trading system from the back up siteTrade orders were received by IDEX Market OperationsTrades were reported and automatically matched and executed with a trade date of October 23.Generated trade confirmations and transmitted to firmsNFX/IDEX trades were automatically processed for clearing and settlement to the IDCH.

INTERNATIONAL DERIVATIVES CLEARING GROUP

Page 16: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested member firms’ back-up connectivity to the ICE Trader electronic trading systemScripted order entry for Cotton, Russell 2000 and Sugar futures contractsTrade management via PTMS and TIPS systems for test tradesTrade messages sent via FIXML to Clearing MembersClearing file submission via AFTS

– Match off files, report files, Large Trader, PCS and SPAN files.

ICE FUTURES US / ICE CLEAR US

Page 17: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested member firms’ back-up connectivity to the ICE Exchange electronic trading system DR siteScripted order entry for Canola, Cotton, Russell 2000, Sugar and Brent futures contractsTested ICE Block and other non trading functionality from DR siteWebICE reporting via Internet portal for deal reporting, position reports, etc.

ICE EXCHANGES

Page 18: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested member firms’ back-up connectivity to the ICE Exchange electronic trading system DR siteTested ECS, AFTS, Crystal Reports, ICE Block and other non trading functionality from DR site.

ICE CLEAR EU

Page 19: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Members tested connectivity to CME GLOBEX trading systemParticipated in post-trade testing - generated a subset of October 22nd trades to member firmsTransmitted trade confirmations from KCBT Clearing Corp.Accepted EFP, change records, PCS and large trader records.

KANSAS CITY BOARD OF TRADE

Page 20: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested via the MEFF production ETS environment

Simulated a failure of their London POP and successfully failed over to the backup system during the test

Members entered trades and received reports

Transfer files were delivered from clearing

Clearing data was restricted and not sent to member firms’ back office systems.

MEFF

Page 21: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Trades were entered for MGEX products into the CME GLOBEX platform and MGEX TEMS system. Trades were processed by MGEX Clearing via the MGEX DR siteTREX trade files were generated by the MGEX DR Clearing Server and placed on the MGEX DR FTP serverThe MGEX DR remote access and FTP servers were accessible with the same logins and passwords as the production system.

MINNEAPOLIS GRAIN EXCHANGE

Page 22: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Tested the SOLA electronic trading system via the Toronto back up site

Orders were entered with an October 23rd trade date

Trades were transmitted to firms via HSVF and ATR protocols

Post-trade transmission to CDCC was not part of the scope of the test.

BOURSE DE MONTREAL

Page 23: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

OCC successfully tested from their back up siteSupported FTP+, Pull/Push, NDM and MQ file connectivityIP addresses and TCP Ports were unchanged, as they were in production for this test Firms submitted file transmissions and received output files.

OPTIONS CLEARING CORP.

Page 24: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

A number of problems were encountered; most were resolved quickly, although some caused an unexpected delay to test progressTypes of problems that were encountered included:

– MQ session ID and MQ channel connectivity problems; messaging and routing of M1 records

– Incorrect firewall configuration parameters, IP addresses/incorrect network configuration

– Firewall access problem with a dynamic vs. static IP address.

IV. PROBLEMS ENCOUNTERED

Page 25: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

– Due to the scope of the exercise being “back up to back up”, some firms did not have back up connectivity links to the exchange (i.e., “Chicago only” disruption scenario), and could not participate in the test scope

– Problem with an exchange application prevented the ability to reset their session

– Incorrect contact name/numbers at firms– Incorrect user ID login/misunderstood how IDs were

configured.

PROBLEMS ENCOUNTERED (CONT’D)…

Page 26: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

– Improper FIX tag input– Member firm server connectivity– Time zone conversion/configuration issue– Access rights for market supervisory workstations in DR

were not set up properly.

PROBLEMS ENCOUNTERED (CONT’D)…

Page 27: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

The futures industry proved that it is capable of successfully orchestrating an industry-wide disaster recovery test

Most problems that were encountered were rectified quickly, although some caused an unexpected delay to the restoration of full processing capabilities

Under real life situations, most problems could probably be resolved within hours or by the next business day.

V. LESSONS LEARNED

Page 28: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

The exchanges and clearinghouses’ internal support processes and procedures worked well

Firms and exchanges indicated that the test helped them:– Identify some internal single points of failure– Tighten up and document their business continuity and

system fail over procedures– Improve test scripts and plans for future tests– Identify/refine pre-test and post-test procedures for

connectivity testing– Better understand the need for cross-training– Test connectivity to/from DR sites.

LESSONS LEARNED (CONT’D)…

Page 29: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Firms must be aware of any environmental impact on their network fire walls caused by test requirements:

– Highlight any environmental impact or expectations on the firms– Pre-register via the FIA registration portal/participate in ping

testing– Have proper network staffing support actively engaged during

the test– Be aware of any firewall impact and make changes accordingly

to accommodate testing.

LESSONS LEARNED (CONT’D)…

Page 30: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

A number of firms apparently did not pre-register and “showed up” for the test at several exchanges:

– They were set up and most tested successfully, however, this placed an additional demand on exchange and clearing house support staffs

– Participation in pre-test ping testing should be mandatory for future test initiatives.

LESSONS LEARNED (CONT’D)…

Page 31: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Survey firms and exchanges for input to future testingAnnounce the details, goals and objectives of the next DR test - Saturday October 29, 2011Broadly “market” future test initiatives to firms’ IT, operations, trading and senior management, to ensure a wider dissemination of test information within all firmsInstitute a version control process to mark test plan/test script changes with a version timestamp and commentary on what was changed.

VI. SUGGESTED NEXT STEPS

Page 32: FUTURES INDUSTRY BUSINESS CONTINUITY AND DISASTER RECOVERY 2010 INDUSTRY TEST RESULTSDR VII November 2010 Compiled and Developed by Tellefsen and Company,

CGConsultants to the Financial Services Industry

2010 FUTURES INDUSTRY DR TEST RESULTS

Provide more clarity and details in test plans/scripts if technical changes will be required by firms (e.g., MQ configuration or IP address changes) ; add an appropriate section to test plan formats.Coordinate the October 2011 date with SIFMA; this facilitates firms to participate that are joint FIA/SIFMA members.

SUGGESTED NEXT STEPS (Cont’d) …