Business Continuity Plan

Corinthian Partners, L.L.C. has developed a Business Continuity Plan describing how the firm will respond to events that significantly disrupt its business. Because the timing and impact of disasters and disruptions are unpredictable, the firm must remain flexible in responding to actual events as they occur. The summary below is provided to clients and counterparties consistent with applicable FINRA requirements.

Contacting the Firm

If after a significant business disruption you cannot contact us as you usually do at (800) 899-8950, please call our alternative number (516) 458-1158 or visit corinthianpartners.com. If you cannot reach the firm through either of those channels, please contact our clearing firm, RBC Capital Markets, LLC, at (201) 413-2000 for instructions on how to access funds and securities, place trades, or transfer cash and securities. Please have your account number available.

Plan Overview

The plan provides for the prompt recovery and resumption of business operations after a significant disruption, safeguarding employees and property, conducting financial and operational assessments, protecting the firm’s books and records, and allowing customers to transact business. The plan addresses data backup and recovery; mission-critical systems; alternative communications with customers, employees, and regulators; alternate physical location of personnel; critical supplier, contractor, bank, and counter-party impact; regulatory reporting; and assured prompt access to customer funds and securities if the firm is unable to continue operations.

RBC Capital Markets backs up the firm’s important records in a geographically separate area. While every emergency situation poses unique challenges driven by external factors, time of day, severity of the disruption, RBC’s stated objective is to restore its own operations and accept new transactions and payments within a reasonable amount of time. Order entry and requests for funds and securities may be delayed during this period.

Varying Disruptions

Significant business disruptions vary in scope. In a disruption affecting only the firm or the building housing the firm, the firm will transfer operations to a local site and expects to recover and resume business within the same day. In a disruption affecting the broader business district, city, or region, the firm will transfer operations to a site outside the affected area and expects to recover and resume business within a two-day period. The firm will communicate updates through corinthianpartners.com or the customer emergency number (516) 458-1158. If a disruption is so severe that the firm cannot remain in business, the firm will assure customers’ prompt access to their funds and securities.

Pandemics, Epidemics, and Outbreaks

Corinthian Partners and Corinthian Partners Asset Management, LLC (collectively, “CP/CPAM”) recognize that pandemics, epidemics, and other outbreaks constitute disruptions of a special character, affecting not only the firm but also its personnel, clients, and vendors. In such circumstances the firm conducts an early and recurring assessment of the situation’s impact on essential operations, monitors third-party vendors, and communicates promptly with personnel about heightened phishing and impersonation risk that typically accompanies such events.

Where personnel work remotely, CP/CPAM requires the use of secure Wi-Fi or VPN connections, prohibits the use of public Wi-Fi for firm work, and limits storage of sensitive non-public information on personal devices to circumstances where authorization and protections are first in place. CP/CPAM continues advertising and supervisory recordkeeping obligations through any remote operating period, conducts regular check-ins with advisory personnel, and updates the Business Continuity Plan as conditions warrant.

Inquiries

For questions about the firm’s business continuity planning, please contact Mitchell Manoff at 212-287-1552 or by email at contact form.