C-PAS, in collaboration with Rehmann, has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business.

Contacting Us

If after a significant business disruption, you are unable to reach us, you should go to www.cpasuma.com for notices and updates. You are also encouraged to contact any C-PAS office listed on the Web site for additional information.

Our Goals

Our business continuity plan is designed to resume operations as quickly as possible, given the scope and severity of the disruption. Our goals include:

• Safeguarding our employees and property
• Protecting the firm's books and records
• Transacting client business with minimum disruption

Areas Addressed

Our business continuity plan addresses the following areas:

• Data back-up and recovery
• Resumption of mission critical systems
• Financial and operational assessments
• Alternative communications with clients, employees and regulators
• Procedures for notifying clients of a service disruption including information on the anticipated length of the disruption and instructions for contacting us
• Alternate physical locations for essential employees
• Employee preparedness training
• Impact on critical suppliers, contractors and service providers
• Regulatory reporting
• Client access to funds and securities

Varying Disruptions

Significant business disruptions can vary in their scope and severity and these factors will dictate our responses:

• Disruptions to our office building or the building housing our office
• Disruptions to the area where our office is located
• Disruptions to the city where the office is located
• Disruptions to an extended region around an office

If necessary, we will transfer our operations to a designated alternate site with the goal of resuming business within one business day. This recovery objective may be negatively affected by the availability of external resources and/or circumstances beyond our control. In either situation, we plan to continue business by transferring operations to our clearing firm if necessary. We will keep clients updated through our web site www.cpasuma.com.

Our Commitment to You

We value your relationship and your confidence in us is extremely important. We want to assure you that in the event of any significant business disruption, access to us is our top priority.

For more information

If you have questions about our business continuity planning, you may contact our Chief Compliance Officer at either: 440.356.4520 or carl.sorboro@rehmann.com.