Business Continuity Statement

Creative Planning (or the firm) has developed a Business Continuity and Disaster Recovery Plan (BCP) which provides guidance for the firm regarding the steps and actions that should be taken in the event of an unanticipated interruption of normal business operations. The BCP includes the recovery, resumption, and maintenance of all aspects of the business, including data backup and recovery; mission critical systems; alternative communications with clients, employees and regulators; critical third-party vendors; executive succession plans; and regulatory reporting.

Creative Planning is an investment advisor and does not perform any type of clearing functions for itself or others, and does not hold customer funds or securities. Custody of all client funds and securities are maintained by independent qualified custodians such as Charles Schwab, TD Ameritrade, and Fidelity. In addition to maintaining client accounts, the custodians also grant customers access to their accounts and deliver funds and securities.

Below are a few examples of what might occur if the firm were to experience a business disruption of varying magnitude:

• If one of our office locations became unavailable or had a power outage, telephone calls would be re-routed to our other offices located across the country. Depending on the situation, employees in the affected location would also be instructed to work from home.
• In the event of a public health crisis that resulted in a high rate of employee absenteeism, the firm would focus available personnel on critical business functions that directly support client needs. Additionally, we would enact our workforce continuity plan which includes a provision for employees to work from home.

Although the firm has taken significant steps to develop and implement sound business recovery practices, after a significant business disruption clients may still experience service disruptions or reduced services or access as the firm recovers. While no contingency plan can eliminate all risk of service interruption or temporarily impeded account access, we regularly assess and update our plans to anticipate and respond to reasonable risk situations.