Page 5 - P&P11-05-2020-with-FAQ-JR

5

Opening New Accounts 72
Other-than-Annual Amendments 72
Form ADV Part 3 Client Relationship Summary (Form CRS) 72
Initial Delivery 72
Ongoing Delivery 72
Method of Delivery 72

Investment Policy Committee 73

Remote Office Supervision 74

Heightened Supervision 75

Information Security Policy 76
Information Security Policy 78
Access Persons 78
Inventory of Technology Infrastructure 78
Security of Technology Infrastructure 79
User Login Security 79
User Access Privileges 80
Email Use Security and Guidelines 80
Mobile Device Usage Guidelines 80
Third Party Vendor Security and Diligence 80
Detection of Unauthorized Activity or Security Breaches 81
Prevention of Unauthorized Funds Transfers 81
Data Back-Up Policies 81
Significant Technology System Disruption Plan 82
Testing 82
Staff Training 82

Business Continuity Plan 83
Business Continuity Plan 84
Emergency Information / Contacts 84
Support Services 84
Alternative Physical Location(s) of Employees 85
Clients’ Access to Funds and Securities 85
Data Back-Up and Recovery (Hard Copy and Electronic) 85
Significant Business Disruptions (SBDs) 85
Approval and Execution Authority 85
Plan Location and Access 86

Operational Assessments 87
Operational Risk 87
Mission Critical Systems 87

Our Firm’s Mission Critical Systems 87
Trading 87
Client Account Information 87

Alternate Communications with Clients, Employees, and Regulators 87
Clients 87
Employees 88
Regulators 88
Regulatory Reporting 88
Regulatory Contact: 88

Death of Key Personnel 88

Pandemics, Epidemics, & Outbreaks 89
General Business Operations 89
Information Security & Remote Operations 89
Third Party Vendors 89
Company Personnel 89

Updates and Annual Review 91

Approval & Signature 91