Business Continuity

Business Continuity Planning Disclosure

Waterford Capital Investment Advisory Services, LLC (WCIAS), provides financial services using computer systems and financial relationships. The events of September 11, 2001 emphasized the importance of the capital markets to our economy. As a result, we have been working to improve our responses to various situations that have the potential to impact our ability to serve you. This disclosure document is designed to provide you with information on how we have approached and/or plan to approach various situations that we may encounter.

Overview of Waterford Capital Investment Advisory Services, LLC
WCIAS, is registered with the US SEC and the Texas State Securities Board. We are a full service Registered Investment Advisory firm(RIA) providing customers with execution services on all major exchanges and access to all major markets. Our third party clearing agent, Southwest Securities, Inc (SWS) and Charles Schwab & Co, Inc. (Schwab) performs certain execution and clearing functions for WCIAS. SWS and Schwab uses various mission critical systems to provide these services to our customers. These systems are housed at one of their data centers, one of their offices, or at a third party service provider, exchange or utility.

First, our business continuity planning (“BCP”) insures the safety, security and accessibility of our employees. The events of 9/11 emphasized the unique skill sets of personnel who work in our industry and the need to put their safety first so that after an interruption they are available to continue serving our customers. In addition to protecting our personnel, our BCP acknowledges that SWS and Schwab preserves our customer data through regular back ups which are moved off-site either via media and/or real time and near real time electronic copies of our data at remote locations. In 1996 SWS added a second data center in one of the suburbs of Dallas which houses their backup hardware/software, real time data copies and back office recovery space. They have constructed high bandwidth networks between the two data centers allowing us to utilize the resources of both centers during normal production, as well as facilitating the real time movement of data from primary data servers to the back up data servers. Finally, where mission critical systems are involved, SWS installed, where possible, redundant connections to the exchanges, utilities and counterparties involved.

Business Continuity Planning Response Scenarios:

The details of our BCP are proprietary and contain information which is confidential and in many cases potentially harmful to WCIAS and our customers if publicly available. The following series of event scenarios are presented to disclose to you our planned approach for dealing with a variety of hypothetical Significant Business Disruptions (SBD’s). Understanding, the number of unknown variables present in each situation, WCIAS in coordination with SWS and Schwab can’t guarantee we will follow these plans.

Scenario: An event occurs that, like 9/11, causes the complete shut down of securities trading, clearance/settlement or other banking services nationwide. (nationwide)

WCIAS, in coordination with SWS and/or Schwab, plans to continue business during this type of event and will await the reopening of affected institutions. Unless a securities industry holiday is declared, we plan to be open each business day until full functionality is restored. The recovery time in this scenario will be dependent on the timing specified by the impacted organizations. We plan to be ready to open when they reopen.

Scenario: A specific exchange is unable to trade. (nationwide)

WCIAS, in coordination with SWS and/or Schwab, plans to continue business during this type of event and will route its order flow away from that exchange to alternative exchanges for the securities that exchange trades. Our recovery time objective for this scenario is less than one hour.

Scenario: One of our major telecommunications vendors loses a key central office or service offering. (nationwide and/or firm only)

WCIAS, in coordination with SWS and/or Schwab, plans to continue business during this type of event and will use alternative dialing options (e.g. placing/receiving local calls through a long distance vendor different from the failed vendor); use backup lines from a different vendor for mission critical data applications (e.g. use the Cox backup connection to our back office when Verizon is down). Our planned recovery time objective is less than four hours.

Scenario: The power grid (ERCOT) is down in Texas. (regional)

WCIAS’s clearing agent, SWS and Schwab plans to continue business during this type of event and will utilize the backup generators that are located at both the primary data center location and the backup data center location to power their operations during the outage. Where necessary, they will relocate personnel among their facilities to compensate for any workspace outages. Their planned recovery time objective for power to our data centers from backup generators is less than fifteen minutes. If they are required to activate their business resumption space for operations recovery, the planned recovery time objective is four hours for mission critical functions.

Scenario: An event occurs that requires our Dallas, TX location to be closed. (regional)

Waterford Capital plans to continue business during this type of event and will transfer its mission critical activities to our alternate office and/or affiliate offices. Our planned recovery times for ordinary business resumption may be negatively impacted by the unavailability of external resources and other circumstances beyond our control.

Customer Access to Funds and Securities:
In the event of a significant business disruption, WCIAS, requests that you first attempt to contact the WCIAS location where you regularly do business. Also, use our website at www.waterfordcapital.com for updated information including alternate contact information.

Dallas
(800) 853-6865 or (214) 363-6920
(214) 616-6391
For Online Customers, if access to your account is not available through www.waterfordcapital.com (e.g. our website is down), attempt to login directly by inputting your regular login information at:

Direct Account Login Web Address: https://myview.swst.com/waterford

If unsuccessful at obtaining information through our Waterford Capital offices, or our websites, our clearing agent (Southwest Securities, Inc) will supply additional information at:

866-SWS-5BCP (866-797-5227)

Updates to this disclosure:
As we continue to test our plans and as conditions in our firm and the industry change, we will continuously revise the plans as considered necessary. Whenever we update this disclosure document we will promptly place a copy of it on our website. You may request a hard copy of this disclosure, in its current revision, be sent to you at any time by mail.

Waterford Capital, Inc.
14175 Proton Road
Dallas, TX. 75244
(214)363-6920
www.waterfordcapital.com