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Business Continuity Plan

FUTURE BENEFITS, INC. BUSINESS CONTINUITY PLAN

 

 

Future Benefits, Inc. hasdeveloped a Business Continuity Plan on how we will respond to events thatsignificantly disrupt our business. Since the timing and impact of disasters and disruptions isunpredictable, we will have to be flexible in responding to actual events as theyoccur.  With that in mind, we areproviding you with this information on our business continuity plan.

Contacting Us – If aftera significant business disruption you cannot contact us as you usually do at800-272-4745, you should call our alternative number 203-506-2190 or go to ourweb site at www.futurebenefits.com forinformation.  If you cannot access usthrough either of those means, you should contact the following companies whereyour assets are held in custody:

Charles Schwab and company at800-515-2157        

Nationwide Insurance Company at800-772-2182

Empower at 800-694-4015

Mass Mutual at 413-744-8411

Paychex at 888-246-7500

John Hancock at 800-395-1113

Our Business Continuity Plan – We planto quickly recover and resume business operations after a significant businessdisruption and respond by safeguarding our employees and property, making afinancial and operational assessment, protecting the firm’s books and records,and allowing our customers to transact business.  In short, our business continuity plan isdesigned to permit our firm to resume operations as quickly as possible, giventhe scope and severity of the significant business disruption. 

Ourbusiness continuity plan addresses: data back-up and recovery; allmission critical systems; financial and operational assessments; alternativecommunications with customers, employees, and regulators; alternate physicallocation of employees; critical supplier, contractor, bank and counter-partyimpact; regulatory reporting; and assuring our customers prompt access to theirfunds and securities if we are unable to continue our business.

All of the Firms that have custody ofour clients assets, back up our important records in a geographically separatearea. While every emergency situation poses unique problems based on externalfactors, such as time of day and the severity of the disruption, we have beenadvised by these firms that its objective is to restore its own operations and beable to complete existing transactions and accept new transactions and paymentsas soon as possible. Your orders and requests for funds and securities could bedelayed during this period.  Thisrecovery objective may be negatively affected by the unavailability of externalresources and circumstances beyond our control.

 

 

 

VaryingDisruptions –Significant business disruptions can vary in their scope, such as only ourfirm, a single building housing our firm, the business district where our firmis located, the city where we are located, or the whole region.  Within each of these areas, the severity ofthe disruption can also vary from minimal to severe.  In a disruption to only our firm or abuilding housing our firm, we will transfer our operations to a local site whenneeded and expect to recover and resume business within 2 hours.  In a disruption affecting our businessdistrict, city, or region, we will transfer our operations to a site outside ofthe affected area, and expect to recover and resume business within 8 hours. Ifthe significant business disruption is so severe that it prevents us fromremaining in business, we will assure our customer’s prompt access to theirfunds and securities by directing you to contact one of the custodians directly.

 

Formore information –If you have questions about our business continuity planning, you can contactus at:

 

Future Benefits, Inc.

1781 Highland Avenue

Suite 205

Cheshire, CT 06410

1-800-272-4745

grenham@futurebenefits.com

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Future Benefits, Inc.

Business Continuity Plan (BCP)

 

I.    Emergency ContactPersons

Ourfirm’s two emergency contact persons are: 

 

KevinGrenham

Office: 800-272-4745, ext.223

Home:          860-562-1868

Cell:   203-506-2190

EMAIL:Grenham@futurebenefits.com alternate K.Grenham@comcast.net

 

ThomasHiten

Office: 800-272-4745, ext.224

Home:          203-272-1613

Cell:   203-506-2188

EMAIL:hiten@futurebenefits.com alternate thiten@aol.com

 

 

 

    These names will be updated in the event ofa material change, and our Chief Compliance Officer will review them at leastannually.

 

 

II.        FirmPolicy

 

  Our firm’s policy is to respond to aSignificant Business Disruption (SBD) by safeguarding employees’ lives and firmproperty, making a financial and operational assessment, quickly recovering andresuming operations, protecting all of the firm’s books and records, andallowing our customers to transact business. In the event that we determine we are unable to continue our business,we will assure customers prompt access to their funds and securities. 

 

A.   Significant BusinessDisruptions (SBDs)

Ourplan anticipates two kinds of SBDs, internal and external.  Internal SBDs affect only our firm’s abilityto communicate and do business, such as a fire in our building. See Appendix Afor procedures for internal SBD. External SBDs prevent the operation of the securities markets or anumber of firms, such as a terrorist attack, a city flood, or a wide-scale,regional disruption.  Our response to anexternal SBD relies more heavily on other organizations and systems, especiallyon the capabilities of our custodial firms.

 

 

 

B.    Approval andExecution Authority

ThomasR. Hiten, Chief Compliance Officer is responsible for approving the plan andfor conducting the required annual review. Kevin W. Grenham, President has the authority to execute thisBCP.

 

C.   Plan Location andAccess

Ourfirm will maintain copies of its BCP plan and the annual reviews, and thechanges that have been made to it for inspection at our office location.  Copiesof the Plan will be distributed to all employees.

 

III.      BusinessDescription

Our firm is an Investment AdvisoryFirm dealing with mutual funds, equity, and fixed income. Our firm does notperform any type of clearing function for itself or others.  Furthermore, we do not hold customer funds orsecurities.  In some cases accept andenter orders.  All transactions are sentto our custodial firms, which executes our orders, compares them, allocatesthem, clears and settles them.  Thesefirms also maintain our customers’ accounts, can grant customers access tothem, and delivers funds and securities.  

 

IV. Office Location

 

Our Office islocated at 1781 Highland Ave, Suite 205, Cheshire CT  06410. Its maintelephone number is 800-272-4745. Our employees may travel to that office bymeans of foot, car, train, and taxi. We engage in all of our services at thislocation.

 

 

V.    Customers’ Access to Funds and Securities

  

Our firm does not maintain custody ofcustomers’ funds or securities, which are maintained at our custodian firms.

 

In the event of an internal orexternal SBD, if telephone service is available, our employees will takecustomer orders or instructions and contact our custodians on their behalf, andif our Web access is available, our firm will post on our Web site that customersmay access their funds and securities by contacting available functionallocations .Alternate methods will be posted if required, such as directions totelephone, or if unavailable, use  email,facsimile or other method to contact the custodians directly.  The firm will make this information availableto customers through its website. 

 

 

VI.  Data Back-Up and Recovery (Hard Copy andElectronic)

 

Ourfirm maintains its primary hard copybooks and records and its electronic records at 1781 Highland Avenue, Suite 205,Cheshire, CT 06410.  Thomas Hiten, ChiefCompliance Officer, 800-272-4745 is responsible for the maintenance of thesebooks and records and Kevin Grenham, President, 800-272-4745 is responsible forelectronic records.  Many primary recordsare maintained at our custodians and are retrievable. 

 

Ourfirm maintains its back-up hard copybooks and records.  These records may bein paper or electronic format. Kevin Grenham, President, 800-272-4745 isresponsible for the maintenance of back-up books and records. A back-up copy ofall records is made daily (Cloud). Our paper records and confirms are keptonsite until they are moved to our storage facility, located @ 243 Blacks Road,Cheshire, CT 06410.  Electronic recordsare also backed up by Information Technology Group, which is replicated to ourback up site daily (Cloud).

 

Inthe event of an internal or external SBD that causes the loss of our paperrecords, we will physically recover them from our back-up site.  If our primary site is inoperable, we willcontinue operations from our back-up site or an alternate location.  For the loss of electronic and paper records,we can recover (via the Cloud) from our back-up site, or, if our primary siteis inoperable, continue operations from our back-up site or an alternatelocation.

 

VII.      Financial andOperational Assessments

 

OperationalRisk

 

In the event of an SBD, we will immediately identify what meanswill permit us to best communicate with our customers, employees, criticalbusiness constituents, critical banks, critical counter-parties, andregulators.  Although the effects of anSBD will determine the means of alternative communication, the communicationsoptions we will employ will include our website, telephone voicemail, regulartelephone, cell phones, and secure email. In addition, we will retrieve our key activity records as described inthe section above, DataBack-Up and Recovery (Hard Copy and Electronic).

 

Financialand Credit Risk

 

In the event of an SBD, we will determine the value and liquidityof our investments and other assets to evaluate our ability to continue to fundour operations.  We will contact our custodians,and investors to apprise them of our financial status.  If we determine that we may be unable to meetour obligations to those counter-parties or otherwise continue to fund ouroperations, we will request additional financing from our bank or other creditsources to fulfill our obligations to our customers and clients.  If we cannot remedy a financial deficiency,we will file appropriate notices with our regulators and immediately takeappropriate steps, including appropriate notification and release of relevantinformation to all interested parties.

 

 

 

 

 

VIII.  Mission Critical Systems

 

Ourfirm’s “mission critical systems” are those that ensure prompt and accurateprocessing of securities transactions, including order taking, entry,execution, comparison, allocation, clearance and settlement of securitiestransactions, the maintenance of customer accounts, access to customeraccounts, and the delivery of funds and securities.  More specifically, these systems include:

 

PerformanceTechnologies: Client account information system

SchwabInstitutional Platform: Electronic Trading System

 

Bothof these systems can be accessed from a remote location and will be testedperiodically.

 

Missioncritical systems for Nationwide, Empower, Mass Mutual, Paychex and John Hancockare maintained by those custodians and are accessible by our clients.

 

Forour Schwab clients, we have primary responsibility for establishing andmaintaining our business relationships with our customers and have soleresponsibility for our mission critical functions of order taking and entry andexecution.  For our other custodialclients, the respective custodian firm provides, through contract, thecomparison, allocation, clearance and settlement of securities transactions,the maintenance of customer accounts, access to customer accounts, and thedelivery of funds and securities. 

 

Allof our custodial firms maintain business continuity plans and the capacity toexecute those plans. 

 

 

IX.       Alternate Communications Between the Firm andCustomers, Employees, and Regulators

 

          A. Clients

 

Wenow communicate with our clients using the telephone, e-mail, our Web site,fax, UPS, U.S. mail, and in person visits at our firm or the client’s location.In the event of an SBD, we will assess which means of communication are stillavailable to us, and use the means closest in speed and form (written or oral)to the means that we have used in the past to communicate with the other party.For example, if we have communicated with a party by e-mail but the Internet isunavailable, we will call them on the telephone and follow up where a record isneeded with paper copy in the U.S.mail. 

 

 

          B. Employees

 

  Wenow communicate with our employees using the telephone, e-mail, and inperson.  In the event of an SBD, we willassess which means of communication are still available to us, and use themeans closest in speed and form (written or oral) to the means that we haveused in the past to communicate with the other party. We will also employ acall tree so that senior management can reach all employees quickly during anSBD.  The call tree includes all staffhome and office phone numbers.  We haveidentified persons, noted below, who live near each other and may reach eachother in person:

 

 

 

 

Theperson to invoke use of the call tree is: Thomas Hiten

 

 

Caller

Call Recipients

 Tom Hiten 203-506-2188

Kevin Grenham   203-506-2190

 

Brian Williams   203-449-8582

 


 

 

Kevin Grenham

William Doran   203-725-8438

 


 


 


 


 





 








 



 


 


 


 


 


 


 

 

 

 





 



 











 


 

 




 

 

          C. Regulators

 

Weare currently members of the following Regulator:

 

 

SEC – Boston Regional Office

617-573-8900

33 Arch Street

23rdfloor

Boston, MA  02110-1424

Paul Levenson, Regional Director

boston@sec.gov

 

 

Weare also responsible for notice filings to the following State Regulators:

 

Connecticut
State ofConnecticut
260 Constitution Plaza
Hartford, CT 06103
(860) 240-8245
www.state.ct.us

Florida
Office of FinancialRegulation
200 East Gaines Street
The Fletcher Building
Tallahassee, FL 32399-0372
(850) 410-9805
(850) 410-9748 (Fax)
www.dbf.state.fl.us/licensing


Massachusetts
Securities Division
One Ashburton Place
Room 1701
Boston, MA 02108
(617) 727-3548
(617) 248-0177 (Fax)
www.state.ma.us/sec/sct/sctidx.htm

New York
Office of the Attorney General
Investor Protection & Securities Bureau
120 Broadway
23rd Floor
New York, NY 10271
(212) 416-8200
(212) 416-8816 (Fax)
www.oag.state.ny.us/investors
/investors.html

 

Wecommunicate with our regulators using the telephone, e-mail, fax, U.S. mail, andin person.  In the event of an SBD, wewill assess which means of communication are still available to us, and use themeans closest in speed and form (written or oral) to the means that we haveused in the past to communicate with the other party.

 

 

X.   Regulatory Reporting

 

Ourfirm is subject to regulation by the regulators listed above in IX, part C. Wenow file reports with our regulators using paper copies in the U.S. mail, andelectronically using fax, e-mail, and the Internet.  In the event of an SBD, we will check withthe SEC to determine which means of filing are still available to us, and usethe means closest in speed and form (written or oral) to our previous filingmethod.  In the event that we cannotcontact our the SEC, we will continue to file required reports using thecommunication means available to us. 

 

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XI.Disclosure of BusinessContinuity Plan

 

Our Business Continuity Plan is postedon our Web site and will be mailed to customers upon request.   

 

 

 

 

 

 

         

 

 

 

 

 

 

 

 

 


 

APPENDIX A

 

TO FUTURE BENEFITS, INC. BUSINESSCONTINUTY PLAN (BCP)

 

PROCEDURES FOR AN INTERNAL SIGNIFICANTBUSINESS DISRUPTION (SBD)

 

 

·       Thomas Hiteninvokes the call tree. Calls are executed.

 

 

 

·       Kevin Grenhamlogs onto New Horizon’s portal as administrator and has all Future Benefitscalls re-routed to each individual employee’s cell phone.

 

 

 

·       Kevin sets up aremote Portfolio Center site and Schwab Institutional Platform in his house.

 

 

 

·       Tom sets up aremote trading system through the Schwab Institutional Platform in his house.

 

 

 

·       Brian Williamssets up an alert page on the Future Benefits Web page with instructions forclients.

 

 

 

·       Brian Williamscontacts the Post Office and UPS to have mail and deliveries re-routed to 29Eastgate Drive (residence of Tom Hiten).

 

 

 

·       William Doranproceeds to Office to assess damage and determine the short and long-termoutlook for the building. Bill reports back to Kevin and Tom and a Plan forContinuity is posted on the Web site. 


 
 


Copyright © Future Benefits, Inc. | 1781 Highland Avenue – Suite 205 Cheshire, Connecticut 06410 | Phone: (800) 272-4745 | Fax: (203) 272-2459
Securities offered through Triad Advisors, Inc..
5185 Peachtree Parkway, Suite 280, Norcross, GA 30092. Member FINRA, SIPC

Advisory Services offered through Future Benefits, Inc. Future Benefits is not affiliated with Triad Advisors.