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Karie M. OConnor,
CIMA®, CPFA®, AIFA®, QKA®

Director – Institutional Advisory Services

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Jeffrey P. DeHaan, CFP®

Managing Partner – Private Wealth Management

Clearwater Capital Completes Cybersecurity Program Review

Jeff DeHaan July 01, 2021

As with many aspects of our lives, Clearwater Capital relies on sophisticated technology to meet the needs of our clients while also keeping the sensitive information gathered in that process safe and secure. Protecting client information is one of our firm’s top priorities, to which we have dedicated a large amount of time and resources. The reason is simple; the Securities and Exchange Commission’s Office of Compliance Inspection and Examinations estimates that 74% of the advisors examined have experienced cyberattacks directly or through one or more of the their vendors.* The bad actors of the world are smart, motivated, and incentivized. Their tactics change frequently, and they are very good at what they do.

As such, Clearwater recently engaged the services of Charles Schwab’s Business Consulting and Education Group to assist us in completing a comprehensive Cybersecurity Evaluation Program. Utilizing the National Institute of Standards and Technology (NIST) Cybersecurity framework as our guide, a team of Clearwater employees representing each functional area of the firm worked with Schwab’s Cybersecurity experts to review, evaluate, and improve our Cybersecurity Policies & Procedures. The team also updated our monitoring processes to further enhance the security of our systems and will continue to monitor the evolution of our business, the industry, technology, and the wide array of threats that exist to proactively make future updates as needed.

While no program is perfect, our review found only minor updates and improvements which reflects the degree of attention that this area of our business has received in the past. While we cannot share the details of our policies, clients of the firm will continue to experience some in action. Secure email transmissions, verbal verifications with the use of security questions, and multifactor authorization on the Clearwater Capital Portal are only the tip of the iceberg that is our Cybersecurity program. We appreciate your patience with these policies as we know they can be cumbersome at times.

In closing, it is our pledge to stay vigilant in protecting our client information. We would also ask that you please be sure to contact us immediately if you ever feel you may be the victim of cybercrime and/or identity theft. We will work with you to safeguard your accounts and your information, which is best done as early as possible.

* Office of Compliance Inspection and Examinations, National Exam Program Risk Alert, Cybersecurity Examination Sweep Summary, Volume IV, Issue 4, February 3, 2015.

Jeff DeHaan

disclosure

THIS COMMENTARY HAS BEEN PREPARED BY CLEARWATER CAPITAL PARTNERS. THE OPINIONS VOICED IN THIS MATERIAL ARE FOR GENERAL INFORMATION ONLY AND ARE NOT INTENDED TO PROVIDE OR BE CONSTRUED AS PROVIDING LEGAL, ACCOUNTING, OR SPECIFIC INVESTMENT ADVICE OR RECOMMENDATIONS FOR ANY INDIVIDUAL. ALL ECONOMIC DATA IS DERIVED FROM PUBLIC SOURCES BELIEVED TO BE RELIABLE. TO DETERMINE WHICH INVESTMENTS MAY BE APPROPRIATE FOR YOU, PLEASE CONSULT WITH US PRIOR TO INVESTING. INVESTING INVOLVES RISK WHICH MAY INCLUDE LOSS OF PRINCIPAL.

This material is not intended to be relied upon as a forecast, research or investment advice, and is not a recommendation, offer or solicitation to buy or sell any securities, insurance products, or to adopt any investment strategy. The opinions expressed are as of the date of writing and may change as subsequent conditions vary. The information and opinions contained in this material are derived from proprietary and nonproprietary sources deemed by Clearwater Capital Partners to be reliable, are not necessarily all-inclusive and are not guaranteed as to accuracy. Past performance is no guarantee of future results. There is no guarantee that any forecasts made will come to pass. Reliance upon information in this material is at the sole discretion of the reader. Investment involves risks. International investing involves additional risks, including risks related to foreign currency, limited liquidity, less government regulation and the possibility of substantial volatility due to adverse political, economic or other developments. Index performance is shown for illustrative purposes only. You cannot invest directly in an index. S&P 500 is a registered trademark of Standard & Poor’s Financial Services, a division of S&P Global (“S&P”)  DOW JONES, DJ, DJIA and DOW JONES INDUSTRIAL AVERAGE are registered trademarks of Dow Jones Trademark Holdings (“Dow Jones”). The two main risks related to fixed-income investing are interest rate risk and credit risk. Typically, when interest rates rise, there is a corresponding decline in the market value of bonds. Credit risk refers to the possibility that the issuer of the bond will not be able to make principal and interest payments.

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