FTAM Funds Distributors, Inc.- Business Continuity Plan

Introduction 

The Firm and its parent organization have developed a Business Continuity Plan to provide procedures for response and recovery in the event of a significant business disruption. The purpose of the Plan is to identify responsible personnel in the event of a disaster; safeguard employees' lives and firm property; evaluate the situation and initiate appropriate action; recover and resume operations to allow continuation of business; provide customers with access to their securities business needs; and protect books and records. The Plan was developed considering the types of business conducted, systems critical to support business, and geographic dispersion of offices and personnel.

Plan Summary 

FIRM, in conjunction with its affiliate, ALPS Fund Services, Inc. ("ALPS"), has a Business Continuity Plan that contains a plan for minimizing the risk of disaster, outlines the chain of command, outlines the recovery process and includes critical information required should a business interruption occur. It is organized in sections that apply to the firm in general and to individual functional areas. The plan is reviewed and updated as necessary in response to a significant change within FIRM.

The Recovery Process 

In the event of a business interruption, the business contingency management committee ("BCMC") assesses the situation, discusses alternatives and begins the recovery process either within the current facilities or at the recovery facility. The infrastructure team is responsible for restoring necessary technology and facility resources. Emergency response teams within each business line or department then implement individualized recovery procedures to restore normal business operations.

Planning and Preparation 

The Business Contingency Management Committee meets several times per year. The meetings serve as a forum to discuss the recovery process, plan for upcoming tests, review recent test results and address any new topics/issues.

Client Data

FIRM's primary protection is the replication of critical data to its recovery facility. Secondarily, FIRM performs intra-day and end-of-day backups of data to a disk array and to a tape library. Tapes are taken off site on a daily basis.

Telecommunications

To protect client telecommunications functionality, FIRM maintains three separate voice T-1 circuits. Traffic can be re-routed between our providers in a very short period of time. If more than one T-1 is not functioning, FIRM can re-route client traffic to a remote facility that can be accessed by FIRM personnel wherever there is telephone service. Internet connectivity is maintained via a primary and a secondary ISP.

Recovery Provider 

FIRM has a contract with Sungard Availability Services to provide for offsite recovery of our systems, In the event of a disaster, FIRM is able to:

1) relocate to a Sungard facility in Colorado (or any other US site)

2) redirect toll-free telephone traffic to a remote facility which can be accessed by FTAM employees from anywhere telephone service is available,

Once at a Sungard Facility, FIRM has access to scheduled equipment including:

- Computers

- Telephones

- Dedicated Internet Access

- Fax Machines/Copiers

- Meeting rooms

- Dedicated Hosted Equipment

On a regular basis the contract is reviewed and modified (if necessary) to meet the changing needs of our business and our clients.

Testing 

The plan is formally tested at least once a year. Each test has a specific focus to insure that all areas receive the proper amount of concentration, Through this testing, we continue to improve the overall effectiveness of the plan,

In addition to annual formal testing, monthly restoration tests and periodic data integrity tests are performed, In addition to annual formal testing, regular restoration tests and periodic data integrity tests are performed. 

Disclosure 

This information is provided solely to our customers and no further distribution or disclosure is permitted without our prior written consent. No person other than our customers may rely on any statement herein.  You may request an updated copy by writing us at the following address: FTAM Funds Distributors, Inc, Compliance Department, 1290 Broadway, Suite 1100, Denver, CO 80203.