Business Continuity Plan
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., and/or TD Ameritrade. Freedom401k Plan Clients accounts and assets are maintained and custodied at Fidelity Institutional Brokerage.
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 & TD Ameritrade 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. Please see the summary of Pershing’s Business Continuity Plan attached hereto. 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. Please see the summary of Fidelity’s Business Continuity Plan attached hereto. 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. Please see the summary of Schwab’s Business Continuity Plan attached hereto. Otherwise, please call CAPTRUST at (800) 216-0645 or you may reach Schwab Institutional Investments directly at: 800.289.5114. Clients may access their accounts by logging into www.schwab.com.
For those CAPTRUST Clients who are utilizing TD Ameritrade as custodian:
Although CAPTRUST recognizes TD Ameritrade as a Critical Business Constituent, TDA’s proprietary web-based platform permits access to your account remotely regardless of a business local, city-wide or regional disruption. Please see TD Ameritrade’s Business Continuity Plan Statement attached hereto. Or you may find the published document at: https://www.tdameritrade.com/disclosure.page. Clients may obtain a current version of TDA’s BCP Statement by contacting CAPTRUST at firstname.lastname@example.org or by writing to TD Ameritrade, Inc., Compliance Dept, PO Box 2148, Omaha, NE 68103-2148.
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://captrust.com) that customers may access their funds and securities by contacting Pershing, Fidelity, Schwab TD Ameritrade directly.