Business continuity statement for Rochester Investments’ clients
Rochester Investments is committed to providing our clients with the highest level of advice, service, and information regarding the investments and assets they have entrusted to us. As part of this commitment, we have developed a Business Continuity Plan to address how we will respond to events that significantly disrupt our business. We recognize how heavily our clients rely on our services and systems. We also recognize that the unexpected can and does occur. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our Business Continuity Plan.

Contacting Us
Please contact us by phone at (585) 568-6656, toll-free 888-306-1671, by email at, or our website at If you cannot access us through either of those means, and if your account is at Charles Schwab, you should contact them at 800-435-4000 for instructions on how they may provide prompt access to funds and securities; place trade orders; and process other trade-related, cash, and security transfer transactions for your account(s). If your account is at a different institution, please contact the custodian listed on your investment statement by calling them directly. Their phone number should be listed on your statement.

Our Business Continuity Plan
We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s records, and enabling our clients to transact business as quickly as possible. Our Business Continuity Plan is designed to permit our firm to assess the scope and severity of any significant business disruption and resume operation depending on the circumstances. Our business continuity plan addresses: data backup and recovery; mission critical systems; financial and operational assessments; alternative communications with clients, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our clients’ prompt access to their funds and securities if we are unable to continue our business.

Our primary custodian, Charles Schwab & Co., Inc., backs up important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our custodians that their objective is to restore their own operations and be able to complete existing transactions and accept new transactions and payments within several hours. Your transactions and requests for funds and securities could be delayed during this period.

Varying Disruptions
Significant business disruptions can vary in their scope, such as a single building housing our firm, the business area where our firm is located, the city where we are located, or the whole 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 the building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within a few hours. In a disruption affecting our business area, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within one business day. In either situation, we plan to continue business, transfer operations to another location if necessary, and notify you through our web site www. or via regular mail or email.

If the business disruption is so severe that it prevents us from remaining in business, we will assure our clients’ prompt access to their funds and securities. If you have an account through our custodian, you may contact Charles Schwab directly at 800-435-4000. If your account is held directly with a mutual fund, insurance or other investment company, you may call the company directly.

Our Business Continuity Plan is reviewed annually to ensure that it accounts for business and regulatory changes, technology, operations, structure, or location. The plan is subject to modification and upgrading by our firm.

For more information
If you have questions about our Business Continuity Plan, you can contact us by writing to Rochester Investments, 1580 W Ridge Rd, Rochester, NY 14615.

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