(1) Data back-up and recovery (hard copy and electronic).
Client files are backed up continuously in multiple secure off-premises locations utilizing cloud-based services. Advisor does not create nor maintain hard copies, as its business operations utilize no paper. Written memoranda and notes are taken via electronic means, namely using an electronic computational device such as a laptop or desktop computer.
(2) Retention of client records.
Advisor retains client records in multiple secure off-premises locations utilizing cloud-based services.
(3) Continuity or termination of operations.
When advisor plans to terminate providing advisory services, advisor will notify clients via a phone call with follow up written notification.
(4) Alternate communications between the investment adviser and.
(A) Its customers.
Clients may contact advisor via email, phone, or by mail.
Michael Grodsky c/o Aquarius Financial
1 Sierra Lejana, Santa Fe NM 87508
phone: 323-293-6800
email: michael@aquariusfinancial.com
(B) Its employees.
Advisor has no employees.
(C) Its investment adviser representatives.
Advisor has no IARs other than the owner.
(D) The Commissioner.
Advisor can use USPS mail, email and phone/fax to contact Commissioner.
(E) The custodian.
Advisor has no relationship or written agreements with custodian of client accounts. Advisor has no discretionary authority over, nor directly deducts any fees from, client accounts. Only FTJ FundChoice has a relationship with the custodian. Only FTJ FundChoice has the written authority to deduct fees from client accounts.
(5) Alternate physical location of employees and investment adviser representatives.
Advisor has no employees or IARs, and there are no alternate physical locations.
(6) Regulatory reporting.
Advisor agrees to file regulatory reportings, such as annual ADV updates at IARD.
(7) How the investment adviser will assure customers’ prompt access to their funds and securities, including prepaid fees, in the event that the investment adviser determines that it is unable to continue its business.
Advisor has no discretionary authority with any client funds. Clients always maintain full access and control of their accounts and funds. Advisor does not utilize prepaid fees with any of its clients. There is never a situation whereby clients do not have continuous access to their funds.
(8) How the investment adviser-will assure customers’ prompt access to their funds and securities, including prepaid fees, in the event of the investment adviser’s or of any of the investment adviser representative’s death or incapacitation, including alternative contact information.
See answer to (7) above. Alternative contact information:
In event Michael Grodsky is not available, advisory clients should contact
FTJ FundChoice, LLC
2300 Litton Lane, Suite 102
Hebron, KY 41048
Company main: (859) 426-2000
FTJ Customer Service Representatives: 800.379.2513, option 4.https://www.ftjfundchoice.com/
(9) How the investment adviser will ensure that no client is charged for advisory services during a period where a client is not receiving advisory services.
When Advisor terminates providing advisory services, advisor will notify clients via a phone call with follow up written notification.
(10) How the investment adviser will ensure that clients and custodians are immediately notified in the event of death or incapacitation of the investment adviser or of any of the investment adviser representatives, or the inability to continue business.
In event of event of death or incapacitation of the investment adviser, the advisor’s wife (Mara Lonner) will notify clients and the third party asset management platform. Advisor has no relationship or service agreement with custodian of client accounts.
(11) A succession plan designed to ensure administration of client accounts after the death or incapacitation of the investment adviser or of any of the investment adviser representatives.
Upon notification of death or incapacitation of the investment adviser, clients may transfer their accounts to any other custodian. Clients are already in full control of their accounts and can do anything they wish at any time by contacting the third party asset platform FTJ FundChoice. Advisor has no discretionary authority over, nor directly deducts any fees from, client accounts. Only FTJ FundChoice has a relationship with the client account custodian. Only FTJ FundChoice has the written authority to deduct fees from client accounts.
(12) Disaster Recovery Plan
The implementation of disaster recovery measures will largely depend on the extent of the communications or operations failure. All client accounts at FTJ FundChoice and at the custodian TDAmeritrade are accessible to clients. Therefore any communications or operations failure on part of Advisor will have no effect upon the continuity or viability of client accounts.
Advisor records are continuously backed up in secure, multiple, off-site locations in the cloud.
Aquarius Financial Business Continuity Plan, version 11/11/2018