Provident Investment Management
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Business Continuity Plan


Summary and objectives:

Provident Investment Management Inc. (“the Company”) has developed this plan to ensure, to the best of its ability, that it will restore reasonable functionality in the event of emergency. This document spells out the Company’s policies and procedures in the event of loss of use of physical premises, computer equipment and communications capabilities.

I. Emergency declaration and initial contact

In the event of an emergency, Scott Horsburgh as President and Chief Compliance Officer, will declare an emergency and serve as the primary contact. Scott will attempt to make initial contact with every employee. Should any material impairment in the Company’s capabilities occur and Scott not make contact, Dan Boyle, Miles Putnam, Pam Parks, and Dan Krstevski may also assume such a role if they have not been contacted within one business day of an apparent emergency.

The attached emergency contact list will be updated as necessary. All employees must report changes of address, phone number, cell phone number or primary email address to Scott.

If broad-scale interruptions prevent us from locating each other, all personnel should contact Fidelity Institutional Wealth Services at 800-523-7166 and use our five-digit code (23525) to reach our service team.

II. Events of emergency

a. Fire

In the case of a fire, be it in the office of Provident or in the building in which Provident maintains its offices, provided the building is safe to enter, all files, records and computers will be transported to the home of Scott Horsburgh until new office space is secured. This residence is capable of supporting business and has phone and internet access. The phone of Provident would be forwarded to the temporary location of the business and all clients would be notified via phone of the situation and our method of response. All communication with vendors takes place via phone and internet in our current offices and would be the same in the case of a residence.

If the building were not safe to enter and all equipment and files were lost, the physical copies of all account agreements would be available from the broker dealer that has custody of the account. Temporary office space would be secured. New computer equipment would be purchased and a restoration of our data using the restoration process of the secure off-site backup solution would take place.

b. Power Outage

In the case of a power outage, the same procedure outlined in the case of a fire would be used if the outage was local or site specific to our offices. If the outage was regional, we would be forced to move our equipment to a location that had power and internet access in order to run the business.

c. Phone/Internet Service Failure

Provident utilizes a phone and Internet service provider utilizing always-on, high-speed, connectivity. This technology allows all methods of communication to be on one line and under the responsibility of one vender. If there was an outage, the employees would use cellular phones and instruct our telephone vendor to forward the main number to one of the phones. Multiple handsets would be required so we would be able to answer the main phone and return the call on another phone, always leaving our main number free for incoming calls. As long as we have phone service, we are able to make trades and manage portfolios.

d. Theft

All information and documents of a confidential nature are maintained in the office of Provident and locked on a daily basis when the offices are closed. The servers that contain confidential information are only accessible by password. In the event that the server was stolen, it could be replaced and uploaded with the data within two business days.

III. Restoration of functionality

a. Scott and all available personnel will assess the degree of impaired functionality and determine the next course of action. This section outlines the plans established to deal with a variety of impaired functions.

b. Alternative premises

i. In the event of loss of use of the current office, Scott’s home will be the initial gathering location.

ii. The post office and custodians of client assets need to be notified of the new address.

c. Critical functions:

i. PortfolioCenter software and database

ii. Client CRM system (“Highrise”)

iii. Client trading and cashiering functions (Fidelity WealthCentral)

iv. Securities analysis (Toolkit software, STKVAL spreadsheet)

v. Office functions (computers, inbound communications, internet connection, corporate accounting)

d. Alternative provisions

i. PortfolioCenter software and database

Backup for PortfolioCenter database is on a remote backup.

ii. Highrise (“CRM”) – cloud-based service accessible from any computer at

iii. Client trading and cashiering functions (Fidelity WealthCentral)

Client trading and cashiering can be accessed via the internet at In the event of further loss of functionality, trading and cashiering can be handled through any Fidelity branch.

iv. Securities analysis (Toolkit software, STKVAL spreadsheet) – backed up to the cloud daily

v. Office functions (computers, inbound communications, internet connection, corporate accounting)

1. Computers – we own and maintain a laptop for emergency use; this laptop contains necessary software to run the mission-critical functions identified in II.c. For temporary use, the Horsburgh household has three computers with basic functionality, including internet connections

2. Inbound communications – clients have been instructed on our annual Form ADV to use our 800 number in the event of an emergency. This number is on the letterhead used in all client communications, on our business cards and our web site. Our telephone carrier, TDI, will be instructed to port the 800-449-6970 number to an alternative landline.

3. Corporate accounting - corporate books and payroll are kept on Quickbooks, an off-the-shelf bookkeeping program. Copies of our Quickbooks database are stored on the cloud.

vi. We have been assured by our IT consultant, N2M Technology, that basic functionality can be restored within 24 hours using established backup/restore procedures.

IV. Data backup and Recovery

a. Provident employs “Mirroring” technology on each data server(s). “Mirroring” implements an additional storage drive that mirrors - a complete copy and duplicate in real-time of each and every action - the main drive and creates a real time on-site backup. If the primary storage drive should fail, the machine will be able to switch to the mirror (additional) storage drive and use it as the primary. This allows for no loss of data and more importantly minimal interruption of business.

b. As a secondary backup, Provident employs the services of a secure, internet based, off-site data backup. This automated backup technology uses a secure internet connection to create a backup of our data server(s) off-site on an ongoing basis each day. This removes the risk associated with fire or theft destroying the data and also allows for data restoration at another location should a disaster occur that requires such a restoration.

c. Finally, Provident has a redundant server prepared to assume the workload should any of the primary server(s) fail. This will allow Provident to continue to operate while any primary server(s) are repaired. These redundant systems allow for Provident to resume essential business operations with little to no interruption of daily business activities.

V. Re-establishment of communications with clients.

a. Personnel not required to handle securities analysis, portfolio management and client needs will contact all clients as soon as possible and by any means possible. We may not have sufficient telephone connectivity at a backup location, and personnel may need to use cell phone or home telephones. Each client will be given alternative contact information, including the cell phone or home phone number of at least two Company personnel.

VI. Other key contacts:

Building management/owners

On-site management – Erica Sturdivant

Management company – CBRE Property Management

Insurance – Meg Spinale Insurance Agency (State Farm) – Chanel Konja

VoIP Technology - Nextiva

Information Technology - N2M Technology

Portfolio Technology - Envestnet Tamarac