Business Continuity Plan

FINRA has adopted rules requiring securities firms to implement plans for the continuation of business in the event of a significant disruption. “Significant disruption” refers to local or regional events such as natural disasters, fires, power outages, acts of malice and technical or infrastructure disruptions. Examples of varying disruptions are noted at the end of this section. However, due to the unpredictable nature of such events, PCS will remain flexible in responding to actual events as they occur.

Contacting PCS: If a significant business disruption occurs in Portland and you are unable to contact us at our normal number, (503) 248-0721, you should contact our Boston office at (866) 293-8894, or go to our website at www.pacific-crest.com. If a significant business disruption occurs in one of our branch office locations, business will continue to be conducted from our main office in Portland.

PCS Business Continuity Plan: PCS has developed and implemented a business continuity plan (BCP) for responding to events that significantly disrupt our business. We plan to quickly recover and resume business operations after a significant disruption. PCS will respond by safeguarding our employees and property, conducting a financial and operational assessment, protecting the firm’s books and records and allowing customers to transact business.

PCS’s plan addresses several areas: safety and well-being of employees; data backup and recovery; mission-critical systems; financial and operational assessments; communications with employees, customers, regulators and critical vendors; alternate physical location; regulatory reporting; vendor impact; and assuring customers prompt access to their funds and securities if PCS is unable to continue its business.

It should be noted that in the event of a significant disruption, PCS is highly dependent on various entities and utilities, including our clearing firm, which PCS has no control over. PCS’s BCP is subject to periodic updates. An updated disclosure notice will be promptly posted to our website as necessary at www.pacific-crest.com. Additional details regarding our policy may be obtained by calling (503) 248-0721.

Clearing Firm Business Continuity Plan: PCS’s clearing firm, NFS, has also taken steps to develop a business continuity plan. NFS has alternate locations from which to conduct business should the need arise. A key element of their plan is to ensure PCS’s clients have prompt access to their funds and securities.

Varying Disruptions: Significant disruptions can vary in their scope, such as only PCS, a single building housing PCS, the business district where PCS is located, the city where PCS is located, or the whole region. Within each of these areas, the severity of the disruption can also vary.

In a significant disruption that only affects PCS or the building housing PCS, we will transfer our operations to our Boston office or a local site if necessary. The PCS emergency contact procedures will be used to pass along critical emergency information to employees. Key personnel will meet as necessary at our designated offsite location. Mission-critical systems will be restored as soon as possible, and customer calls will automatically be forwarded to the offsite location or our Boston office. PCS will attempt to resume basic business services, such as customer access to funds, within 24 hours.

In a significant disruption that affects the business district, city, or region where PCS is located, we will transfer our operations to a site outside of the affected area. The PCS emergency contact procedures will be used to pass along critical emergency information to employees. Management will assess the situation and work to restore mission-critical systems. Customer calls will be forwarded to an external location. Depending upon the severity of the disruption, employees from Portland may travel to other locations and/or work from home to assist with business recovery. PCS will attempt to resume basic business services as soon as possible given the facts and circumstances.

In either situation, we plan to continue in business and provide information to you through our website or emergency numbers. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers’ prompt access to their funds and securities.

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