business continuity plan.
We recognize it's not possible to create a plan to handle every possible eventuality, but it's our intent to set up a framework to be used in the most likely of scenarios. It is also the intent that this framework provide guidance as to how to respond should an unforeseen situation occur.
We believe an adviser's fiduciary obligation to its clients includes the obligation to take steps to protect the clients' interests from being placed at risk as a result of our inability to provide advisory services after, for example, a natural disaster or, in the case of some smaller firms, the death of the owner or key personnel. The clients of an adviser that is engaged in the management of their assets would ordinarily be placed at risk if the adviser ceased operations.
Business Description
Core Planning conducts investment advisory services; we do not hold custody over customer funds or securities. Transactions are sent to a custodial brokerage firm, which executes the orders, compares them, allocates them, clears and settles them.
The custodian maintains its clients’ accounts, grants clients access to them, and delivers funds and securities.
Emergency Information
Firm Contact Persons
Core Planning's emergency contact person is:
Guy Penn
636-734-7507
guy@corepln.com
Managing Member and Chief Compliance Officer (CCO)
Alternative firm contact in case of death of above Key Personnel:
Lei Deng
314-800-4923
lei@corepln.com
This information will be updated in the event of a material change, and the CCO will review the plan on an annual basis.
Firm Policy
Core Planning’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 the firm’s books and records, and allowing its clients to transact business.
In the event that we determine we're unable to continue our business, we will assure clients prompt access to their funds and securities.
Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our ability to communicate and do business, such as a fire in our place of business or the death of a key member of the firm. External SBDs prevent the operation of the securities markets for a number of firms, such as a national emergency, or a wide-scale regional disruption.
Core Planning‘s response to an external SBD relies more heavily on other organizations and systems, such as the brokerage firm(s) and Internet Service Providers it uses.
Approval and Execution Authority
The CCO is responsible for approving the plan and for conducting the required annual review. The CCO has the authority to execute this BCP.
Plan Location and Access
Core Planning maintains copies of its BCP and annual reviews, and all changes that have been made. A physical copy of this BCP is stored with the company’s Policies and Procedures Manual, which is kept in the following location: In the Managing Member’s Office on the shelf behind his desk in a Red Binder (cliche, we know). An electronic copy of this plan is stored: As a PDF file on the firm’s cloud drive within a folder entitled "Business Continuity Plan" which is a sub-folder of the Regulatory Folder, itself a sub-folder on the main drive.
Each access person is given a copy of the plan and notified of the location/file within Core Planning’s electronic systems to which employees have access.
Custodian and Brokerage Firm Contacts
TD Ameritrade Institutional 200 South 108th Ave.
Omaha, NE 68154
(800) 400-6288
Location of Physical Records
Core Planning's primary physical records are held at the address below:
710 Diamond Pointe Ct. O’Fallon, MO 63366
Clients’ Access to Funds and Securities
Core Planning does not maintain custody of clients’ funds or securities, which are maintained at the custodial brokerage firm. In the event of an internal or external SBD, if telephone service and internet service are available, Core Planning investment adviser representatives (IARs) will take customers’ orders or instructions from any remote location. If internet access is available, we will e-mail clients information about how they may access their funds and securities.
Data Back-Up and Recovery (Hard Copy and Electronic)
We will maintain our primary hard copy books and records and our electronic records at the physical location or records listed above.
The firm’s CCO is responsible for the maintenance of these books and records. We must maintain the following document types and forms that are not transmitted to our custodial brokerage firm: Investment Policy Statements, Client Contracts and other related client servicing documents.
The firm backs up its electronic records daily by online digital backup and keeps copies on external hard drives located at the workplace of the firm’s Managing Member.
Operational Assessments
Operational Risk
In the event of an SBD, we will immediately identify what means will permit us to communicate with our clients, employees, critical business constituents, and regulators.
Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include website, telephone voice mail, secure e-mail, etc. In addition, we will retrieve key activity records as described in the section above, Data Back-Up and Recovery (Hard Copy and Electronic). Employees will establish contact with the firm’s Emergency Contacts and communicate key firm directives as they apply to operating the business whether it be from a new location, each employee’s residence or an alternative regional location with access to a different power grid from the principal office.
Mission Critical Systems
Core Planning's “mission critical systems” are those that ensure client communication, access to client accounts and trading systems. More specifically, these systems include the office computer systems.
We have a primary responsibility for establishing and maintaining our business relationships with our clients. Our custodian provides the execution, comparison, allocation, clearance and settlement of securities transactions as well as the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities.
Our custodian contract provides that the brokerage firm/custodian will maintain a business continuity plan and the capacity to execute that plan.
The custodian represents that it backs up our firm records at a remote site. As well, our custodian represents that it operates a back-up operating facility in a geographically separate area with the capability to conduct the same volume of business as its primary site. It has also confirmed the effectiveness of its back-up arrangements to recover from a wide scale disruption by testing.
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.
The Firm’s Mission Critical Systems
Trading
Core Planning uses the electronic order entry system provided by its custodian or another third party to enter trading activity and transactions. If electronic means are not available, we may place orders by telephone, in which case order tickets will still be maintained.
In the event of an internal SBD, we will enter and send records to the custodian by the fastest alternative means available. In addition, during an internal SBD, we may need to refer our clients to deal directly with the custodian trade desk for order entry.
Alternate Communications with Clients, Employees, and Regulators
We communicate with our clients, with each other, and with regulators using the telephone, e-mail, U.S. mail, and in person visits.
In the event of an SBD, we will assess which means of communication are still available and use the means closest in speed and form (written, electronic, or oral) to the means that it has used in the past to communicate with the other party.
Regulatory Reporting
Core Planning is subject to regulation by the state of Missouri and other jurisdictions as applicable.
We file reports with our regulators using the IARD/CRD System. In the event of an SBD, we will check with the state of Missouri and other jurisdictions as applicable to determine which means of filing are still available, and use the means closest in speed and form (written or oral) to its previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available and forward those reports at the earliest opportunity.
Regulatory Contact:
Missouri Secretary of State Securities Division
600 West Main Street, Room 229 Jefferson City, MO 65101
(573) 751-4136
Death of Key Personnel
The following personnel are identified as “Key Personnel” without which it would be difficult to continue operating the firm and/or properly service clients:
Guy Penn
Managing Member & Chief Compliance Officer
If some event made it impossible for the personnel listed above to continue to service the firm, Core Planning would implement the following succession plan:
Lei Deng would be designated as CCO and will be in contact with any and all impacted clients to ensure those clients are served by either herself or another IAR of Core Planning, LLC. Lei Deng would contact the state of Missouri Secretary of State Securities Division to inform them of the change of personnel and new firm CCO.
Updates and Annual Review
Core Planning will update this plan whenever it has a material change to its operations, structure, business or location or to those of its custodial brokerage firm.
In addition, the CCO will review this plan annually, to modify it for any changes in its operations, structure, business, or location or those of its custodial brokerage firm.
Better to have and not need, than to need and not have...