Business Continuity Plan

Our firm has developed a Business Continuity Plan ("BCP") on how we will respond to events that significantly disrupts our ability to provide advisory services to clients. Based on the facts and circumstances of our Firm's business model including our size, services we provide, and location, the timing and impact of disasters and disruptions will be unpredictable. However, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our BCP.

Contacting Us

If after a significant business disruption you cannot contact us as you usually do at (303) 539-9077 or toll-free (877) 697-7500, you should call our alternative number (303) 810-8899, or go to our web site at If you cannot access us through either of those means, please refer to the list below for the contact information for your particular investment account or custodian.

Contacting the Custodial Firm

In the event you cannot reach us in the manner listed above and you have a brokerage account held by our custodial firm, please contact the firm directly for assistance in accessing your funds and securities or to place trades.

Custodian Name
Contact Info
Shareholders Service Group (SSG)(800) 380-7370

Assets Held at Other Companies

If you hold assets directly with another fund company or investment manager (not through our clearing firm) you should contact that company directly for instructions on how to access your funds and securities, place trades or process any other account maintenance or servicing needs. Information on how to contact the company can usually be found on the monthly or quarterly statement sent to you by the custodian of your account assets. Companies with whom you have securities investment accounts are required to provide you with Business Continuity Statements that give information on how to contact the company in the event of a significant business interruption. If you have not already received a Business Continuity Statement from any company holding an account for you, we recommend that you contact the company to request the statement so that you have it on hand.

Our Business Continuity Plan

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding all personnel and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical business constituent, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business. Our custodial firms, SSG, back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our custodial firms that their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments according to their time sensitivity. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within one day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within one to three business days. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site or our primary contact number. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities. Please note that our business continuity plan is reviewed as necessary, and at least annually, to ensure it accounts for technology, business and regulatory changes, operations, structure or location. The plan is subject to modification. An updated business continuity statement for clients will be promptly posted on our website. You may also obtain a current written copy of the updated statement by contacting us directly.

For more information

If you have questions about our business continuity planning, you can contact us at (303) 539-9077.

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