The scope of VALIC Financial Advisors, Inc. (VFA) business continuity planning today entails certain key VFA business operations and data center locations. Business continuity planning is the process which defines the procedures employed to ensure the timely and orderly resumption of a company’s business, through its ability to execute plans with minimal interruption to time-sensitive business operations.
How well VFA is prepared to survive a business disruption with minimal interruption to its daily routine will depend on the elements identified and the provisions made for review, maintenance, quality assurance and accuracy of its business continuity plans. Specific plans have been developed and teams have been identified for each time-sensitive business operation. Each plan prioritizes the critical business functions and states a strategy for recovery within a specified timeframe.
AIG’s Enterprise Resiliency department is responsible for the guidelines, methodologies, and framework to support the strategies for recovery. VALIC’s business units and application support teams are responsible for developing and maintaining continuity plans that are compliant with the above-mentioned guidelines, methodologies, and framework.
VFA Business Continuity Objectives
The objectives of the VFA Business Recovery Continuity Plan are to:
- Support health and well-being of staff.
- Provide a framework for controlled and timely responses to incidents.
- Document recovery strategies to minimize impact to staff, customers and business.
- Minimize commercial and reputation damage.
- Protect account assets and financial position.
- Minimize the risk of legal liabilities.
- Resume and recover any disrupted business function or operation rapidly and effectively.
- Ensure compliance with all applicable laws and regulations.
- Maintain confidence and good relations with public safety and regulatory agencies, customers, service providers, and other official parties.
- Satisfy the interests and concerns of VFA programs and other related business entities.
VFA Business Continuity Guidelines
The VFA Business Continuity Plans were developed in accordance with the AIG Enterprise Resiliency Policy. The AIG Enterprise Resiliency Policies are based on industry standard. The key elements of the policy include Business Impact Analysis, Business Continuity Plan, and Plan Testing.
These key elements are discussed below:
- Business Impact Analysis – Each VFA business unit is required to identify and follow the Criticality Tier Matrix to define the criticality of each business function, as well as the requirements such as internal & external dependencies and applications that the function needs to successfully recover. Additionally, each unit must review the Business Impact Analysis annually.
- Business Continuity Plan – VFA business units document and update annually a continuity plan to support the recovery of the business function/process. Continuity plans should be documented in accordance to the Enterprise Resiliency Policy and Standards and align to the Criticality Tier Matrix which can include documenting recovery procedures, employee communication strategies, alternate site requirements, procedures for notifying clients, recovery management, and alternate site preparation checklists.
- Plan Testing – Once the Business Continuity plan documentation is complete, it is tested regularly to ensure that recovery capability remains viable. Testing requirements and frequency are driven by the Criticality Tier Matrix.
VFA Recovery Strategies
Threats that materialize can cause varying degrees of outages. The VFA recovery strategies address loss of workspace, loss of technology, and loss of staff.
VFA Disaster Recovery
VALIC’s parent company, AIG, has implemented a two data center self-recovery strategy. Business applications are in production mode in one data center with fail-over to the second data center. The two data centers are geographically dispersed with one in Fort Worth, Texas and the other in Livingston, New Jersey.
VFA and its clearing firm, National Financial Services, LLC (NFS), have an agreement in which NFS may provide trade execution, clearing, and other related services for your brokerage account. NFS backs up VFA’s 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, VFA has been advised by NFS that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments in a timely manner.
VFA is also the Broker/Dealer of record on many accounts held directly at third-party mutual fund and annuity companies. These third-party companies each have their own business continuity plan in place in case normal business operations are interrupted for any reason.
In the event VFA ceases operations, customers who have retail accounts with NFS may call the VFA customer service line at 866-544-4968. VFA customers who have accounts held directly with third-party mutual fund or annuity companies should call those companies directly if they need to place a trade, request a distribution, or have questions about their account. Clients who have VALIC Annuity Accounts should contact the Contact Center line at 800-448-2542.
VALIC Financial Advisors, Inc., member of FINRA, SIPC and an SEC-registered investment advisor.