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., or other third party  qualified custodian chosen by the client.

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.

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.

All Personnel Contact Information is contained within AlertMedia.

Key contacts are identified within the Critical Incident Response Team  Plan.