Business Continuity Plan Disclosure

CapFinancial Partners, LLC, doing business as CAPTRUST Financial Advisors, (“CAPTRUST”) is a federally registered investment adviser. In general, CAPTRUST provides investment advisory services on a nondiscretionary/consultative basis to large retirement plans  and other institutions who assets are held at various banks, trust companies, broker/dealers and insurance companies that are determined by the institutional client.

CAPTRUST has an affiliated broker/dealer, CapFinancial Securities, LLC (“CFS”), registered under the Securities Exchange Act of 1934. CFS provides brokerage services (on an ancillary basis) to clients  of CAPTRUST. CFS utilizes the clearing & custodial services of Pershing, LLC (“Pershing”). Throughout this document, specific reference may  be made to CFS (or “BD”). Since  CFS business is connected to clients of CAPTRUST, CFS is also covered by this Business Continuity Plan.

CAPTRUST wealth and other institutional advisory clients, have  elected  to have  their accounts with Pershing Advisor Solutions (Pershing, LLC), Fidelity Institutional Brokerage Services, Charles Schwab & Co., Inc., or other third party  qualified custodian chosen by the client.

CAPTRUST summarizes the manner with which  CAPTRUST’s Business Continuity Plan (“BCP”) addresses the possibility of significant business disruptions (“SBD”). Accordingly, CAPTRUST furnishes this document to clients  in order to provide information about  our efforts  to minimize the impact  of an emergency, business disruption or disaster on the business of CAPTRUST.

In general, industry regulations require  firms  to create  and maintain a business continuity plan reasonably designed to meet its obligations to its clients  or other counter-parties.  In accordance with these  requirements, CAPTRUST has designed a business continuity plan to address possible scenarios in efforts  to minimize any service impact  to our clients.

In keeping with the regulatory requirements, the business continuity plan for CAPTRUST is designed to address key areas of concern – including but not limited to the following:

• Data  back-up and recovery;
• Mission critical systems;
• Financial and operational assessments;
• Alternate means of communication between CAPTRUST and its clients; Alternate means of communication between CAPTRUST and its employees; Alternate physical locations of employees;
• Critical business constituent, bank  and counter-party impact;
• Regulatory reporting;
• Communications with regulators; and
• How CAPTRUST will ensure that customers have  access to their funds  and securities in the event CAPTRUST determines it is unable to continue its business.

Since  events creating business disruptions may  vary  in nature  and scope,  CAPTRUST has anticipated scenarios in which  the following are affected:

• A primary CAPTRUST building at its headquarter location
• A CAPTRUST branch location
• A city wide area
• A regional area

Regardless of the scope of potential disruption, CAPTRUST intends to continue to provide service to its clients.

In the event  of a significant business disruption, where  the primary building or business district is located,  we will move our staff from affected  offices to the closest of our unaffected offices.  The firm has several other locations from which  to conduct business. Therefore, should the primary building or business district be affected  by a disruption, the other locations can be used  to help restore operations.

In the unlikely event  of a citywide  or regional disruption, several of CAPTRUST’s other locations (“established recovery sites”)  are in other cities relatively close  in proximity. The first established recovery site is approximately 4 miles  from its headquarters and is located  within Tierpoint’s data center  in Raleigh. The second is approximately 170  miles  from its headquarters (in Charlotte NC) and the other is approximately 400  miles  (Atlanta  GA).  All alternate locations can be used  to restore  time sensitive functions as soon  as key employees are relocated to the facility.  In the event  that any such disruption occurs,  we have  developed alternative service arrangements, systems, locations and contingency plans  to ensure that any service is quickly  restored.

CAPTRUST has identified several computer applications with Mission Critical or High  criticality ratings and has documented this within the business continuity plan.

Some Mission Critical systems such  as computer applications are proprietary to services providers such as Pershing (i.e., Next360). Pershing provides an annual BCP disclosure to CAPTRUST clients  who are on the PAS  platform.  However, Pershing Advisor Solutions BCP Disclosures are attached as an addendum to CAPTRUST’s BCP Plan. Similarly, Schwab, & Fidelity provide BCP disclosures to CAPTRUST clients  utilizing  those  Institutional Advisory platforms. The BCP Summaries/Disclosures for those  providers are also attached as addendums CAPTRUST’s BCP Plan.

For  those CAPTRUST Clients who are  utilizing Pershing custodian:

Although CAPTRUST recognizes Pershing as a Critical Business Constituent, Pershing’s proprietary web-based platform  permits access to your account remotely regardless of a business local, city-wide or regional disruption. Otherwise, you may  call CAPTRUST at 800-216-0645 or you may  reach  Pershing Advisor Solutions at 201-413-3635. Clients  may  access their accounts at  www.pershing.com.

For  those CAPTRUST Clients who are  utilizing Fidelity as custodian:

Although CAPTRUST recognizes Fidelity as a Critical Business Constituent, Fidelity’s  proprietary web- based platform  permits access to your account remotely regardless of a business local, city-wide  or regional disruption. Otherwise, you may  call CAPTRUST at 800-216-0645 or you may  reach  Fidelity directly  at 800-343-3548. Client may  access their accounts by logging into www.fidelity.com.

For  those CAPTRUST Clients who are  utilizing Schwab custodian:

Although CAPTRUST recognizes Schwab as a Critical Business Constituent, Schwab’s proprietary web- based platform  permits access to your account remotely regardless of a business local, city-wide  or regional disruption. Otherwise, please call CAPTRUST at 800-216-0645 or you may  reach  Schwab Institutional Investments (Wealth Clients)  directly  at: 800-435-4000. For Institutional clients, you may reach  Schwab at 877-362-0410. Clients  may  access their accounts by logging into www.schwab.com.

While CAPTRUST understands that no contingency plan can eliminate all risk of service interruption or temporarily impeded account access, we continually assess and update our plans  to mitigate all reasonable risk.

At a minimum, the CAPTRUST business continuity plan is reviewed, updated and tested  on an annual basis.   Additionally, our primary internal  and external application providers periodically conduct testing of their own back-up capabilities to ensure that, in the event  of an emergency or significant business disruption, they will be able to provide us with the critical information and applications we need  to continue or promptly resume our business. When testing our plan, we review  the recovery time and resumption time period  for all mission critical systems.

Making sure  that any type of disruption does  not unduly impact  our clients  is extremely important to us, and our business continuity plan is designed to allow us to continue to provide the quality  service you have  come  to expect  from CAPTRUST.

In the event  of an internal  or external SBD, if telephone service is available, our registered persons will take customer orders or instructions 919-870-6822 (local) or 800-216-0645 (toll-free) and contact our clearing firm on their behalf, and if our Web access is available, our firm will post on our Web site (https://www.captrust.com) that customers may  access their funds  and securities by contacting Pershing, Fidelity, and Schwab directly.

All Personnel Contact Information is contained within AlertMedia.

Key contacts are identified within the Critical Incident Response Team  Plan.

Schwab Business Continuity Plan Disclosure

Schwab Business Continuity Contingency Planning

Securities industry regulations require that brokerage firms inform their clients of their plans to address the possibility of a business disruption that potentially results from power outages, natural disasters, or other events. Charles Schwab & Co., Inc. has a comprehensive business continuity program in place, which is reviewed, updated, and tested on a regular basis. The program provides for continuation of client service within minutes in most cases.

Here are a few examples of what might occur if Schwab were to experience a business disruption of varying magnitude:

• If one of our telephone service centers became unavailable for any reason, calls would be immediately rerouted to our other service centers across the country.
• If we had a power outage in a particular region or business district, telephone and electronic communications would be immediately and seamlessly re-routed to alternate locations for the duration of the outage.
• In the event of a public health crisis that resulted in a high rate of employee absenteeism, Schwab would focus available personnel on critical business functions that directly support client needs. Additionally, we would enact our workforce continuity plan which includes social distancing and other policies to limit exposure.
• Comprehensive plans are maintained to facilitate timely restoration of account services in the unlikely event of a technology disruption. These plans are tested regularly to ensure their viability.

While no contingency plan can eliminate all risk of service interruption or temporarily impeded account access, we continually assess and update our plans to mitigate all reasonable risk.

The Charles Schwab Corporation provides a full range of brokerage, banking and financial advisory services through its operating subsidiaries. Its broker-dealer subsidiary, Charles Schwab & Co., Inc. (Member SIPC), offers investment services and products, including Schwab brokerage accounts. Its banking subsidiary, Charles Schwab Bank, SSB (member FDIC and an Equal Housing Lender), provides deposit and lending services and products. Access to Electronic Services may be limited or unavailable during periods of peak demand, market volatility, systems upgrade, maintenance, or for other reasons.
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Fidelity Institutional Notice of Business Continuity

Fidelity is committed to providing continuous customer service and support; however, we recognize that there are potential risks  that could disrupt  our ability to serve you. We are confident that we have taken  the necessary steps that will allow us to reduce or eliminate the impact  of a business disruption.

Fidelity recognizes the responsibility we have  to our customers. We have  implemented a business continuity management program with a strong governance model  and commitment from senior management. Our continuity program’s primary objectives are to meet the needs of our customers, maintain the wellbeing and safety  of our employees and meet our regulatory obligations. The planning process is risk based and involves the understanding and prioritization of critical operations across the firm, the anticipation of probable threats,  and the proactive development of strategies to mitigate the impact  of those  events.

Our continuity planning teams work closely with local governments and officials  in the event  of an outage impacting our operations. Additionally, Fidelity has identified three large  scale  scenarios that require  particular focus: pandemics, events impacting stock  and bond  market operations, and cyber events. Detailed response plans  have  been  developed and cross-discipline teams have  been  trained to address both day-to-day disruptions as well as these  specific events.

Each  Fidelity department has developed the capabilities to recover both operations and systems. All continuity plans  are designed to account for disruptions of various lengths and scopes, and to ensure that critical functions are recovered to meet their business objectives. Critical business groups operate from multiple  sites. Dedicated teams within our technology organizations ensure that critical applications and data have  sufficient redundancy and availability to minimize the impact  of an event. Key components of Fidelity’s continuity and technology recovery planning include:

• Alternate physical locations and preparedness
• Alternative means to communicate with our customers
• Back-up telecommunications and systems
• Employee safety  programs

Plans  are tested  regularly to ensure they are effective  should an actual event  occur. Fidelity’s Business Continuity Plans  are reviewed no less than annually to ensure the appropriate updates are made to account for operations, technology and regulatory changes. To obtain  a copy  of this notice at any time, contact  a Fidelity representative.

Fidelity Brokerage Services LLC and National Financial Services LLC, Members NYSE,  SIPC

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