Disclosures

SFA’s Public Disclosures

Keen & Pocock’ s Business Continuity Plan Disclosure

Keen & Pocock has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – In the event of a significant business disruption, our phone number (703-691-9200) will forward calls to an emergency backup number.  If for some reason you are still unable to access us, please contact the entity which custodies your assets.  If you do not know who this is or how to contact them, please contact us now so that you will have that information in the event of an emergency.

You can also contact our broker/dealer, The Strategic Financial Alliance, Inc. at 678-954-4000 for instructions on how they may assist you in contacting the vendor that custodies your assets.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees 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; alternative physical location of employees; critical supplier, 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.

Each mutual fund (e.g., American Funds), insurance company, variable annuity company, Direct Participation company and all Third Party Managers back up important records in a geographically separate area.  Our clearing firm, Pershing LLC, also backs up our important records in a geographically separate area for those brokerage accounts opened thru our broker/dealer, The Strategic Financial Alliance, Inc.  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 clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments unless circumstances dictate otherwise.  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 24 hours. 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 five business days. In either situation, we plan to continue in business, transfer operations to our broker/dealer if necessary and notify you through available reasonable methods.  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.

For more information – If you have questions about our business continuity plan, you can contact us at 703-691-9200.