#HOLISTIC NICOLE OFF GRID CODE#

Moreover, Section 206 of the Act, among other things, prohibits investment advisers from engaging in any device, scheme, or artifice to defraud any existing or prospective client. In this regard, Section 204A of the Investment Advisers Act of 1940 (“Act”) requires investment advisers to establish, maintain, and enforce policies designed to prevent the misuse of non-public information by the investment advisor and its supervised persons. It is enforced to ensure that no one is taking advantage of their position, or even giving the appearance of placing their own interests above that of the accounts, clients, and shareholders we are serving. a federally registered investment adviser (CIRA).

#HOLISTIC NICOLE OFF GRID CODE#

This Code of Ethics (the Code) expresses the policies and procedures of Cambridge Investment Research Advisors, Inc. Therefore, it is important that clients are aware of Cambridge’s revenue sharing arrangements when working with their financial professionals to evaluate their investment options.Ĭlick here to view the complete Revenue Sharing Disclosure. Although Cambridge endeavors at all times to put the interest of its clients ahead of its own or those of its officers, directors, or financial professionals (“affiliated persons”), these arrangements present a conflict of interest that has a potential to affect the judgment of Cambridge or its affiliated persons when making investment decisions. Cambridge has various arrangements with some Approved Product Companies, referred to as revenue sharing arrangements. We collectively refer to these companies as Approved Product Companies. (hereinafter, collectively referred to as Cambridge) offer a wide variety of products and programs including mutual funds, annuities, life insurance, and investment wrap programs. and its affiliates, including Cambridge Investment Research Advisors, Inc. An updated summary will be promptly posted on our website and customers may alternatively obtain updated summaries by requesting a written copy by mail at 1776 Pleasant Plain Road, Fairfield, Iowa 52556.Ĭambridge Investment Research, Inc. This plan is subject to modification, without notice. It is possible for circumstances to arise outside of what has been defined within the Plan.

Certain situations may arise that affect outside entities upon which we rely for some service or collaboration. The unpredictable nature of disasters precludes absolute preparedness for any plan.

Regardless of all the effort put forth on this vital concern, we acknowledge that no disaster recovery plan is perfect. In the event of an SBD, these backups will be obtained and restored as necessary. Mission-critical systems are defined by Cambridge. The communication options we will employ may include our website, telephone voice mail, secure email, and US postal mail service.Īll mission-critical systems are backed up and a copy is stored offsite. In the event of an SBD, either external or internal, Cambridge shall establish an ordered dependency list and begin immediately communicating pertinent information with our clients, employees, critical business constituents, critical banks, critical counter-parties, and regulators. In the event of an SBD where you are unable to reach Cambridge and you have an account held directly at one of the firms with which we have an agreement, you are encouraged to call the custodian's direct number found on your account statement. Our firm does not maintain custody of clients' funds or securities, which are maintained at our clearing firms or held directly at other firms, including but not limited to mutual fund companies and insurance companies. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firms, National Financial Services LLC and Pershing LLC, and other sponsor providers with whom we have agreements. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, or a wide-scale, regional disruption. Internal SBDs affect only our firm's ability to communicate and do business, such as a fire in our building. Our Plan anticipates two kinds of SBDs, internal and external. The Plan is intended to comply with obligations pursuant to regulatory rules and requirements as promulgated by the Financial Industry Regulatory Authority (FINRA), particularly Rule 4370. Cambridge's Plan is designed to respond to a Significant Business Disruption (SBD) by safeguarding employees' lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm's books and records, and allowing our customers to transact business. The Business Continuity Plan Summary Disclosure Statement ('the Plan') provides a summary detail on Cambridge's risk mitigation strategy in the event of interruption(s) to daily business operations.

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