Contacting us
If, after a significant business disruption, you cannot contact us as you usually do through your advisor at his or her local office, you should call our alternative numbers—Waltham: 800.251.0080 or 800.237.0700; San Diego: 877.347.1982 or 877.347.1983—or go to our main website at www.commonwealth.com. If the business disruption is limited to your advisor’s local area, you may access your funds and securities and enter transactions directly through Commonwealth’s Waltham, Massachusetts, or San Diego, California, service centers.

In the event the business disruption affects Commonwealth’s Waltham headquarters location, we will post a bulletin on www.commonwealth.com, advising you of the status of our operations and providing you with instructions on how you may access your funds and securities.

If you cannot access us through any of the means described above, you should contact our clearing firm, National Financial Services LLC (NFS), at 617.563.5977, or, if your account is carried at Pershing, contact Pershing at 201.413.3635. The clearing firm will provide you with instructions on how to access your funds or securities, enter orders, or process other account-related transactions.

Our business continuity plan
We plan to quickly recover and resume business operations after a significant business disruption and to respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. A cross-functional team of senior personnel is responsible for evaluating any disruption and instituting the appropriate plan of action.

Our business continuity plan addresses data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank, and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Commonwealth and our clearing firms, NFS and Pershing, back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as the time of day it occurs and the severity of the disruption, we have been advised by our clearing firms that their objective is to restore their own operations and to be able to complete existing transactions and accept new transactions and payments within four hours of a local, non-severe business disruption. Our objective is to restore our operations within a similar time frame. Your orders and requests for funds and securities could be delayed during this period.

It is important to note, however, that the scope and impact of a local or regional disruption can vary significantly, and certain elements of our and our clearing firms’ recovery plans may require a longer recovery period, which means your requests for funds or securities could be further delayed. During a business disruption, we will continually evaluate, estimate, and communicate the recovery time necessary to resume operations.

As an added safeguard, certain transactions routinely handled by our clearing firms can be performed by us, such as the withdrawal and disbursement of funds from non-NFS custodian retirement accounts. Commonwealth’s recovery plans place a high priority on preserving this capability to support our commitment to provide you with prompt access to your funds during a significant business disruption.

Varying disruptions
Significant business disruptions can vary in scope; for example, they can impact only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the entire region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or to a building housing our firm, we will transfer our operations to a disaster site, if needed, and we expect to recover and resume critical business functions within several hours. In a disruption affecting our Waltham, Massachusetts, home office business district, city, or region, we will transfer our critical business operations to our San Diego, California, operations center, which maintains an independent telephone system and a direct, dedicated line connection to our clearing firms. It is expected that such a transfer will be accomplished immediately and will provide you with immediate and ongoing access to your funds and securities.

In either situation, we plan to remain in business, transfer operations to our clearing firm, if necessary, and notify you through our website, www.commonwealth.com, or our customer contact numbers, 800.251.0080 or 877.347.1983, about how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities by whatever means available to us.

Important disclaimers
Commonwealth will adhere to the procedures described in its business continuity plan and described above to the extent commercially reasonable and practicable under prevailing circumstances. There are, however, an incalculable number of events or circumstances that could result in a significant business disruption, and their impact may vary greatly in size, scope, severity, duration, and geographic location. Further, significant business disruptions may result in varying degrees of harm to human life and regional or national infrastructure (power, transportation, communications, etc.), which could affect the firm’s recovery in significant and different ways.

In light of this, Commonwealth, in its sole discretion, reserves the right to flexibly respond to any disruption in a situation-specific and prudent manner. Nothing in this disclosure document is intended to provide a guarantee or warranty regarding the actions or performance of the firm, its computer systems, or its personnel in the event of a significant business disruption.

For more information
If you have questions about our business continuity planning, you can contact us by writing to Commonwealth Financial Network, 29 Sawyer Road, Waltham, MA 02453-3483, or by calling us at 781.736.0700.