Business Continuity Plan (BCP)
Our Business Continuity Plan (“BCP”) is designed to enable Fiduciary Capital Management Company, LLC (“FCM”) to resume operations as quickly as reasonably practicable following a significant business disruption, taking into account the scope and severity of the disruption.
Our BCP addresses, among other things:
- Data backup and recovery
- Mission-critical systems
- Financial and operational assessments
- Alternative communications with clients, employees, and regulators
- Alternate physical locations for employees
- Critical supplier, contractor, banking, and counter-party impacts
- Regulatory reporting obligations
- Assuring clients’ prompt access to their funds and securities if we are unable to continue business operations
In the event of a significant business disruption, we will take appropriate steps to safeguard our employees and property, conduct a financial and operational assessment, protect the firm’s records, and enable our clients to transact business as quickly as possible.
Custodians
Fiduciary Capital Managment LLC is a Registered Investment Adviser (“RIA”) and may utilize one or more of the following qualified custodians:
- LPL Financial
- SEI Trust Company
- Altruist
- AssetMark
- Interactive Brokers
Each custodian maintains its own business continuity and disaster recovery plans and backs up critical records in geographically separate locations. While every emergency situation presents unique challenges based on factors such as the time of day and the severity of the disruption, we have been advised by our custodians that their objective is to restore operations and process existing and new transactions within several hours. During this period, client transactions or requests for funds or securities may be delayed.
Varying Types of Business Disruptions
Significant business disruptions may vary in scope, including disruptions limited to our firm or building, our business district, our city, or an entire region. The severity of any disruption may range from minimal to severe.
- Firm- or building-specific disruption: We will transfer operations to an alternate local location, if necessary, and expect to resume business within several hours.
- City- or region-wide disruption: We will transfer operations to a location outside the affected area and expect to resume business within one business day.
In either scenario, we will seek to continue operations, transfer business functions as appropriate, and notify clients through our website at www.fiduciarycm.com or via regular mail.
In the Event of a Fiduciary Capital Management LLC Business Disruption
If a disruption is so severe that Fiduciary Capital Management LLC is unable to continue business operations, we will take reasonable steps to ensure our clients have prompt access to their funds and securities. Clients whose accounts are maintained with a qualified custodian may contact the custodian directly. Clients whose investments are held directly with a mutual fund, insurance company, or other investment issuer should contact that company directly.
Plan Review and Updates
Our Business Continuity Plan is reviewed at least annually and updated as necessary to reflect changes in business operations, regulatory requirements, technology, firm structure, or location. The plan is subject to modification and enhancement at any time.
Additional Information
If you have questions regarding our Business Continuity Plan, please contact us by email at support@fiduciarycm.com or by completing the contact form on our website.