Disclosures

The Wellspring Group & Affiliates
Business Continuity Plan Summary

The Wellspring Group and our affiliates - Wellspring Wealth Management and Wellspring Associates - are committed to providing timely service to our clients. We recognize the importance of preparing for various disaster scenarios that could hamper our ability to provide service. We have taken aggressive steps to provide for business contingency and continuity planning under a variety of potential scenarios. We continue to evaluate our continuity plans and take the necessary actions to ensure the proper resources are available to provide for the recovery and timely resumption of critical business operations to internal business units, third-party business partners, and clients.

Wellspring Business Continuity Strategy

Offices and Staff

Wellspring has offices and staff located in Atlanta and Dallas. The Atlanta office serves as the primary site for accounting, compliance, HR, and research. These functions, while vital to the business on a continuing basis, are not considered mission-critical for the daily operation of our business. In the event of a disaster that would make the Atlanta office unserviceable, the Dallas office is its alternative facility.

Mission-Critical Departments

Both the Atlanta and Dallas offices serve as primary locations for our mission-critical departments, including: Operations, Transaction Execution and Processing, and Support. Each office serves as the backup for the other. There are documented and tested plans in place to provide for a failover between the two sites.

The Wellspring main data center is located in the Atlanta office. The alternate data center is located within the firm's Dallas location.

  • The main data center infrastructure is fully redundant in terms of power, network, and equipment.
  • The office in Dallas also provides redundant network systems.
  • There is redundant connectivity between Atlanta and Dallas.

Wellspring's client service, policy service, account service, and brokerage service computing platforms are operated in various geographical regions of the United States by unaffiliated third-party vendors (such as insurance carriers, investment custodians, and broker-dealers). None of the scenarios presented in this document would pose a threat of business disruption to these sites. The third-party vendors have complete business continuity plans that include alternative sites and recovery times within a few hours.

Business Scenario Preparedness

Office Disruption

If Wellspring loses the ability to perform business at either the Atlanta or Dallas location, mission-critical Atlanta functions would be failed over to our Dallas office and vice versa. Staff associated with non-mission-critical functions will be relocated to an alternative site in an unaffected area. We have plans in place for this relocation and they are tested periodically. Recovery time objectives vary based on the criticality of each function.

Access to Your Policy, Accounts and/or Funds

A site outage should not impact our clients' ability to access their policies, accounts, or available funds, as Wellspring's business contingency plans are designed to ensure sustained service. However, the ability to trade securities may be impacted by market events outside the control of Wellspring, such as when the market was closed following the September 11 tragedy. Our tested business continuity plans result in necessary personnel being available to approve transactions that result in the disbursement of available funds. In the event that your Wellspring advisor ceases operations due to a significant business interruption, you may call your insurance carrier, account custodian, or investment provider for emergency assistance.

Conclusion

Please be aware that, while we have detailed plans in place, we cannot guarantee that we will be successful in achieving recovery in the times noted above. For example, we may not be able to implement a plan during a disaster as quickly as we expect, or there may be disasters that we have been unable to anticipate and for which we have no plan. Additionally, if parts of our plan are dependent upon third parties, we will have no control over the success or failure of the third party to respond appropriately to the challenges posed at the time of the disaster.

Our continuity plans are periodically updated and modified. Updated plan summaries will be made available on our websites (www.wellspringgroupllc.com and www.wellspringassociates.com) and can be obtained by submitting a written request to The Wellspring Group, 2200 Century Parkway, Suite 750, Atlanta, Georgia 30345.