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IMPORTANT DISCLOSURES
Business Continuity Plan
Disclosure to Clients and Investors
Cohen Asset Management, Inc. ("CAM") maintains a Business Continuity Plan ("BCP") that
provides a course of action for the assessment of a significant disruption to business
and for the continuation of business following such an event. The BCP consists of
company-wide and departmental disaster recovery plans and includes the formation of the
CAM Incident Management Team ("IMT"). The IMT would serve as the central source of
coordination and communication in the event of a significant disruption to our business.
During such an event, the IMT would first ensure the health and safety of our employees,
and would then oversee the re-establishment and continuation of business processes pursuant
to the BCP. The IMT is responsible for evaluating the disruption, instituting the appropriate
plan of action, and coordinating recovery efforts.
The BCP is designed to address significant business disruptions of varying scope including,
but not limited to:
- CAM-only business disruption
- Disruption to a single building in which CAM business is conducted
- Disruption to a business district in which CAM business is conducted
- City-wide business disruption
- Regional disruption
- National disruption
In each of these scenarios, CAM's BCP provides for an evaluation of the scope of the
business disruption, and sets forth various plans of action and recovery facilities for
the continuation of the firm's business, as well as, alternative means for the dissemination
of information to employees and clients and investors. The BCP serves as a guide that
addresses how CAM will continue to conduct business during each of the above scenarios,
to the extent that is possible pursuant to the IMT's evaluation.
It is CAM's intention to minimize the recovery time necessary to resume operations. CAM
conducts regular testing of the recovery of its back-up facilities and systems in order to
ensure clients and investors will be able to access their information within a reasonable
time following a significant business disruption. Clients and investors should be assured
they will have prompt access to their information through CAM's back-up systems.
The BCP is subject to modification based on changing circumstances and assessment of need.
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