Business Continuity and Disaster Recovery Policy
The framework for sustaining critical operations during disruption, recovering systems and data, and meeting recovery time and recovery point objectives for limited partners and portfolio companies.
- Policy Owner
- Chief Technology Officer
- Approving Body
- Audit Committee
- Effective Date
- January 1, 2026
- Last Reviewed
- June 1, 2026
- Next Review
- January 1, 2027
- Version
- 1.0
Purpose
The Business Continuity and Disaster Recovery Policy describes the firm's framework for maintaining critical business operations during disruptions, recovering systems and data following an incident, and ensuring continuity of service to limited partners and portfolio companies. The policy supports the firm's regulatory obligations under Rule 206(4)-7 under the Investment Advisers Act of 1940.
Scope
This policy applies to all critical business functions of MajorWave, LLC and its affiliates, including investment operations, fund accounting, limited-partner reporting, capital-call and distribution processing, valuation, compliance, and portfolio-company oversight.
Critical Functions
The firm has identified critical functions including capital-call processing, distribution wire processing, limited-partner reporting and portal access, quarterly valuation, portfolio operations oversight, cybersecurity monitoring, and regulatory reporting. Each critical function has a designated owner, recovery time objective, and recovery point objective.
Recovery Objectives
The firm targets a recovery time objective of four hours and a recovery point objective of one hour for capital and distribution processing; eight hours and one hour for LP reporting and portal access; and 24 hours and 24 hours for administrative functions.
Backup and Redundancy
Fund accounting, LP data, valuation records, compliance records, and portfolio operating data are backed up to geographically dispersed secure infrastructure on a continuous or daily basis, with encrypted transmission and encrypted rest. Backup integrity is tested on a rolling schedule.
Alternate Work Sites
Personnel are equipped for full remote operation across the platform. In addition, the firm maintains alternate physical work sites in the Dallas metropolitan area and in a secondary market for use in the event of a regional disruption.
Third-Party Dependencies
Critical third-party service providers, including the fund administrator, the auditor, custodian banks, and the LP Portal provider, are required to maintain and test their own business continuity plans and to report material disruptions promptly to the firm.
Testing
The business continuity plan is tested at least annually through a full-scale exercise and quarterly through targeted table-top exercises. Findings are reviewed by the Audit Committee.
Communications
The firm maintains internal, portfolio-company, and limited-partner communication protocols for use during a disruption, including out-of-band communication channels, an emergency contact register, and a predefined limited-partner notification template for material events.
Governance
The Chief Technology Officer owns the plan and reports to the Audit Committee at least annually and following any material invocation or exercise.