Page 84 - P&P11-05-2020-with-FAQ-JR

84

Business Continuity Plan
Policy
As part of its fiduciary duty to its clients and as a matter of best business practices, CIS, has adopted policies and
procedures for disaster recovery and for continuing CIS's business in the event of an emergency or a disaster.
These policies are designed to allow CIS to resume providing service to its clients in as short a period of time as
possible. These policies are, to the extent practicable, designed to address those specific types of disasters that CIS
might reasonably face given its business and location.

Our firm’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
all of the firm’s books and records, and allowing our clients to transact business. In the event that we determine
we are unable to continue our business, we will assure clients prompt access to their funds and securities.

Background
Since the terrorist activities of 9/11/2001, all advisory firms need to establish written disaster recovery and
business continuity plans for the firm’s business. This will allow advisers to meet their responsibilities to clients as a
fiduciary in managing client assets, among other things. It also allows a firm to meet its regulatory requirements in
the event of any kind of an emergency or disaster, such as a bombing, fire, flood, earthquake, power failure or any
other event that may disable the firm or prevent access to our office(s).

While it is recognized it is not possible to create a plan to handle every possible eventuality, it is the intent of this
firm to set up a framework to be used in most likely of scenarios. It is also the intent that this framework provide
guidance as to how to respond should an unforeseen situation occur.

Business Description
CIS conducts business in equity, fixed income, and derivative securities. We do not hold customer funds or
securities. We manage client portfolios with discretion. All transactions are sent to the RIA’s custodian, which
executes our orders, compares them, allocates them, clears and settles them. Our custodian also maintains our
clients’ accounts, can grant clients access to them, and delivers funds and securities.

Emergency Information
Our brokerage firm contacts:
Schwab – 877-774-3892

Firm Contact Persons
Our firm’s two emergency contact persons are:

John Riley 972-563-8990 johnr@cornerstoneri.com
Kara Kelleter 401-714-6726 kara@cornerstoneri.com

Support Services
In the event of an emergency, the following is a list of support services and the methods by which they may be
contacted:
Emergency Services (EMS): 911
Fire Department: 911
Police Department: 911
Firm Attorney Jim Simmons – 401-272-5800
Firm Accountant John Smith 972-935-6354
Firm Computer Technician – Microsoft Answer Desk – 800-642-7676
AT&T – 1-800-288-2020
Verizon – Business Channel Manger – Nicole Romero – 774-504-4794

This information will be updated in the event of a material change, and our Chief Compliance Officer (CCO) will
review the plan on an annual basis.