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Payden & Rygel has developed a Business Continuity Plan to ensure that all critical functions continue in the event of a disruption in normal operations.
The firm has configured data replication servers and related infrastructure in its Boston, Massachusetts office. Data on critical Los Angeles servers is replicated to corresponding servers in the Boston location on a live basis throughout each day. In addition, other servers and databases are backed up, sent electronically to Boston, and restored at the end of each day. The firm has established a dedicated high-speed connection between the Los Angeles and Boston offices to facilitate the secure transmission of data backups.
A number of individuals from the Trading, Portfolio Operations, Information Technology, Compliance and Portfolio Management departments have been selected to connect remotely to the Boston office to complete their daily responsibilities, in the event of a disruption to normal business operations. The firm has implemented a VMWare virtual environment for each of these individuals, so they have their own remote desktop in Boston to which they securely connect using a laptop or desktop computer with an Internet connection. Our expectation is that routine business operations will resume within 24 hours of a business continuity event. In addition, the Boston office has capacity to accommodate additional employees if a physical relocation of selected Los Angeles employees is necessary.
The firm uses a third-party hosted mass notification system to quickly communicate with all employees in the event of a disruption in operations. The system allows management to compose a text or voice message notifying employees of the event, which is then sent automatically to employees' mobile phones, home phones, and e-mail addresses. Employees indicate their receipt of the message from their phone or mobile device, which allows management to immediately review summary reports of the employees who are aware of the disruption. Additional instructions and updates can then be sent to all staff, as necessary under the circumstances.
In the event that our Business Continuity Plan is activated and Los Angeles office phone lines are down, the Los Angeles phone numbers are re-directed to the Boston office. Boston-based staff will direct callers to the mobile phones of key portfolio professionals, as necessary. All key investment personnel have access to firm e-mail on mobile devices. E-mail delivery to Payden & Rygel addresses is not dependent on the availability of either Los Angeles or Boston servers. Finally, Boston-based staff has access to portfolio management and reporting information independent of Los Angeles technology availability.
The transfer agent for the Payden Funds is not located in Payden & Rygel's offices. The transfer agent for all of the funds maintains all shareholder records and will continue to receive all shareholder calls related to their accounts.
On at least a quarterly basis, several employees from the departments specified above will remotely connect to the Boston office to test the infrastructure by conducting their daily job responsibilities, including the execution, ticketing, settlement and processing of securities trades.
The Business Continuity Plan was developed and is monitored by a committee of senior managers, including the heads of the Trading, Portfolio Operations, Compliance and Information Technology departments. The committee meets regularly to discuss any necessary updates to the Plan and coordinates ongoing tests of the Boston location by a team of employees from various departments. The committee also solicits feedback from personnel based on the ongoing tests and promptly makes adjustments to the Plan and the Boston office resources, as necessary. Updates to the Business Continuity Plan will be posted on this website page and a copy of the Plan may also be obtained by written request.