Securities industry regulations require that financial firms inform their clients of their plans to address the possibility of a significant business disruption ("SBD") that potentially results from power outages, natural disasters, or other such events. BBVA Global Wealth Advisors, Inc. ("GWA") must be able to provide continuous, uninterrupted services to its clients, and the firm's critical systems must operate during such interruptions so that the Adviser resumes operations as quickly as possible, given the SBD's scope and severity. GWA must meet its obligations to clients, counterparties, and other business relationships during an emergency or SBD.
Since the timing and impact of disasters and disruptions are unpredictable, GWA must also be flexible in responding to actual events as they occur. Well thought out, advanced preparations and effective procedures efficiently minimize downtime in the face of a disaster or outage and enable the firm to meet existing client obligations.
Firm Policy
To satisfy this requirement, GWA has developed a comprehensive Business Continuity Plan ("BCP"), which is reviewed, tested regularly, and updated no less than annually to detail how it will respond to an SBD event and assist clients in making educated decisions about whether to conduct business with us. GWA's guiding principle is that protecting clients, employees, and family members always takes precedence over preserving business assets. The firm's policy is to respond to an SBD by first safeguarding clients' and employees' lives and firm property. Then, make a financial and operational assessment, quickly recover and resume operations, allow clients to continue transacting business, and protect the firm's books and records.
If it is determined that the firm cannot continue its business, we will promptly advise our clients and other business relationships and assist them with the next steps as appropriate for our business model.
BCP Summary
While no contingency plan can eliminate all risks of service interruption, GWA's BCP strives to mitigate all reasonable risks while keeping up with changes to the firm's operations, structure, business, and location (as applicable). Our BCP - which is subject to revision - anticipates two kinds of SBDs: internal and external.Internal SBDs affect only the firm's ability to communicate and do business, such as a fire in the building. External SBDs prevent the operation of the securities markets for several firms and include a terrorist attack, a city flood, or a wide-scale regional disruption.
GWA's BCP addresses mission-critical systems, office closing/relocation procedures, and the alternative physical location of employees. Operational risk systems and assessment procedures are defined to ensure continued communication with clients and employees and our critical business constituents, banks, counterparties, and regulators. A Succession Plan is in place in the event of key personnel absence, as are procedures for the safety of the data back-up and recovery of firm books and records. Further, GWA requests its primary internal and external application providers to periodically test their back-up capabilities to ensure that they can promptly provide the critical information and applications needed to continue or resume the firm's business in an emergency or SBD situation.
When a minor or significant event occurs or appears to be developing, GWA's Disaster Recovery Executive Coordinator ("DREC") will be notified. Upon notification or becoming aware of an SBD event, the DREC will implement BCP emergency procedures, secure the headquarters as much as possible, refer to actions contained within our complete BCP, and advise all employees to either call the firm's emergency call line directly at 415-463-0434 or contact the DREC directly.
If a business disruption affects only GWA or a specific building within the firm, GWA will transfer its operations to a local worksite. In a disruption affecting the firm's business district, city, or region, operations will be transferred to an alternate worksite outside of the affected area. In either situation, GWA plans to continue conducting business and notify its clients how to contact the firm through a voice message reached via its main phone number and notification provided on its website. Telephone service will continue at any alternate worksites, and regular work processes will resume at the alternate location(s).
Recovery times may vary depending on the nature and severity of the disruption; however, the recovery time objective for mission-critical operations is 0-72 hours.
If the significant business disruption is so severe that it prevents the firm from conducting business, GWA will update its voice message and website appropriately, according to the BCP's provisions.
Contacting Us & More Information
Our Business Continuity Plan is designed to allow us to continue to provide the quality service you have come to expect from GWA. Questions about our Plan should be directed to:
BBVA Global Wealth Advisors, Inc. 501 Brickell Key Driv, Suite 601 Miami, FL 33131 Telephone: 434-242-0068
