Business Continuity Plan

Cassel Salpeter & Co., LLC (“Cassel Salpeter”) has developed a Business Continuity Plan (“BCP”) on how our firm will respond to events that significantly disrupt our business.

Since the timing and impact of disasters and disruptions are unpredictable, our firm has an obligation to prepare for unforeseen events as they occur. Our BCP is designed to permit our firm to resume operations in a reasonable amount of time at a secure remote location, given the scope and severity of a major event.

VARYING DISRUPTIONS

If a business disruption affects only our firm or a specific building within our firm, we will transfer our operations to a local worksite. In a disruption affecting our business district, city, or region, we will transfer our operations to an alternate worksite outside of the affected area. In either situation, we plan to continue conducting business and notify our clients how to contact us through a voice message reached via our main phone number. In order to accommodate our recovery time objective, telephone service will continue at the alternate worksite and normal work processes will resume at the alternate worksite. Recovery times may vary depending on the nature and severity of the disruption; however, our recovery time objective for mission critical operations is 0-72 hours. If the significant business disruption is so severe that it prevents us from conducting business, we will update our voice message.

CONTACTING US

At a minimum, the Cassel Salpeter business continuity plan is reviewed and updated 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. Our businesscontinuity plan is designed to allow us to continue to provide the quality service you have come to expect from Cassel Salpeter.

Privacy Policy

INFORMATION COLLECTION AND USE

Cassel Salpeter recognizes how important it is for you to feel confident in the knowledge that your personal financial information is secure. We are committed to protecting and safeguarding the personal and financial information that you have entrusted to us. In the course of doing business with clients, Cassel Salpeter may collect confidential information about clients. “Confidential personal information” is financial and any other information about our clients that is non-public and personally identifiable such as name, address, date of birth, or social security numbers. Such information may also include the amount of your investments, representations about your assets and income you made and representations of sources of your funds.

WHAT INFORMATION CASSEL SALPETER WILL DISCLOSE AND TO WHOM CASSEL SALPETER WILL DISCLOSE THAT INFORMATION

Cassel Salpeter may disclose confidential information about clients as may be permitted or required by applicable laws or regulations. Accordingly, it may disclose confidential information about clients:

  • To government entities, in response to subpoenas, information requests, or to comply with applicable laws or regulations;
  • When clients instruct, or consent to, Cassel Salpeter making such disclosure; and
  • To service providers that perform services for Cassel Salpeter, such as our external auditors, outside counsels, and service providers that process or service Cassel Salpeter transactions (including custodians, broker-dealers, prime brokers, third party administrators and banks).

INFORMATION ABOUT FORMER CLIENTS

Even if a client no longer has an account with Cassel Salpeter, we will adhere to the privacy policies and practices described in this notice.

HOW CASSEL SALPETER SAFEGUARDS INFORMATION

Within Cassel Salpeter, access to confidential information about clients is limited to our employees, and in some cases to third parties (for example, the service providers described above) as may be permitted or required by applicable laws or regulations. Cassel Salpeter and service providers maintain physical, electronic and procedural safeguards to guard clients’ confidential information. If this Privacy Policy changes in any material way, you will be notified through appropriate means. If you have questions or comments about our privacy policy, please call us at (305) 438-7700 for further information or explanation.