I. Emergency Contact Persons
Our firm’s two emergency contact persons are Greg Welborn, President, who can be directly contacted at 626 665 6517, firstname.lastname@example.org, and Scott Sommers, Vice President, who can be directly contacted at 626 484 1492, email@example.com.
II. Firm Policy
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, and protecting all of the firm’s books and records. In the event that we determine we are unable to continue our business, clients’ prompt access to their funds and securities will not be affected.
A. Significant Business Disruptions (SBDs)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only our firm’s ability to communicate and do business, such as a fire in our building. External SBDs affect multiple firms over a wider area, such as a city flood, or a wide-scale, regional disruption, or a terrorist attack. Our response to an external SBD relies more heavily on other organizations and systems.
B. Approval and Execution Authority
Greg Welborn, President, is responsible for approving this plan and for conducting the required annual review. He and Scott Sommers, Vice President, have the authority to execute this BCP.
C. Plan Location and Access
Our firm will maintain a copy of its BCP plan and will make it available to clients and regulators. An electronic copy of our plan is located on our internal cloud in the common files folder, instructions sub-folder, as well as on our website at www.firstfinancial.is
III. Business Description
Our firm provides financial planning and investment consulting services. We do not hold client funds or securities, do not have discretion over client accounts, and do not stipulate which custodian(s) clients must use for their investment accounts. We do not offer any private placements of limited partnerships.
IV. Office Locations
Our only office is located at 517 S. Lake Avenue, Pasadena, CA 91101. Our main telephone number is 626 844 4630. Our employees may travel to that office by means of car, bus, metro and foot.
V. Alternative Physical Location(s) of Employees
In the event of an SBD, our staff is directed to conduct business from their individual residences until such time as we re-open our existing office location or lease a suitable replacement site. Our phone and email systems are maintained by different vendors, as are each advisor’s mobile number. Additionally, many custodians maintain their records at multiple locations, purposely scattered geographically.
VI. Customers’ Access to Funds and Securities
Our firm does not maintain custody of customers’ funds or securities. They are maintained at the custodian(s) chosen by each individual client. An SBD affecting our company would not affect our clients’ ability to access their accounts or information.
VII. Data Back-Up and Recovery
Our firm maintains its primary accounting books and records on an Intuit server. Intuit automatically backs up the financial records and data with automatic offsite storage in the cloud, using multiple servers. Each server is housed securely with a full-time 24-7 security staff, video surveillance and alarms. Intuit’s network operation centers (NOC) have secure power supplies and backup generators in case of a power cut, as well as complex smoke and flood detection and fire suppression systems.
Our firm maintains its financial statements and tax returns on an on-site computer, and a back up is maintained with Carbonite, a back-up service provider. Carbonite also automatically backs up this information to multiple facilities which are protected by a full-time, 24-7 security staff. Carbonite’s facilities have secure, fully redundant power supplies and backup generators.
Our firm maintains primary client information on two geographically separate SalesForce servers. These server locations are secured by around-the-clock guards, maintain on-site back-up generators, and are designed to withstand the adverse weather phenomenon endemic to their specific location.
Our firm maintains certain additional client information on an on-site computer, which is backed up by Carbonite, a back-up service provider.
All clients maintain their own financial data and provide copies to our firm as needed. Accordingly, an SBD affecting our company would not affect our clients’ ability to access their own financial data.
All clients select their own custodian(s), which maintain account information. Clients have access to this information by paper statements and/or electronic access as provided by the custodian(s) selected. An SBD affecting our company would not affect our clients’ ability to access their accounts or information.
In the event of an internal or external SBD, we will recover our records by accessing from our personal computers, while domiciling at our residences or a replacement site, the respective servers referenced above in this section.
VIII. Financial and Operational Assessments
A. Operational Risk
In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, bank, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include telephone, email and facsimile, as appropriate. In addition, we will retrieve our key activity records as described in section VII above.
B. Financial and Credit Risk
In the event of an SBD, we will determine the value and liquidity of assets to evaluate our ability to continue to fund our operations. We do not have a capital requirement. We will contact critical banks and investors to apprise them of our financial status. If we determine that we may be unable to continue to fund our operations, we will request additional financing from our bank or other credit sources to fulfill any obligations to our clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take appropriate steps, including those protections afforded us under state and federal laws, but a capital deficiency would not impact our clients’ ability to access or control their financial data or investment accounts.
IX. Mission Critical Systems
Our firm’s “mission critical systems” are those that allow us to communicate with our clients. More specifically, these systems include office phones, advisors’ mobile phones, and email, each of which is maintained by a separate vendor.
The “mission critical systems” of the custodian(s) selected by our clients are maintained by the respective custodians.
X. Alternate Communications Between the Firm and Customers, Employees, and Regulators
We now communicate with our customers using telephone, email, Federal Express and U.S. mail. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by email but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail.
We now communicate with our employees using telephone, email and U.S. mail. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. The President and Vice President will each attempt to call the other in order to determine how employees should be contacted. In the event that the President and Vice President cannot communicate with one another, each bears the responsibility to begin attempting to contact all employees.
We are currently members of FINRA, a self-regulatory organization (SRO), and we are also regulated by the Broker-Dealer/Investment Advisor Division of the California Department of Business Oversight. We communicate with our regulators using phone, email, Federal Express, and U.S. mail. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party.
XI. Critical Business Constituents, Banks, and Counter-Parties
A. Business constituents
We have contacted our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and determined the extent to which we can continue our business relationship with them in light of an internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm. Our major suppliers are:
- TPx Communications (office telephone): 213 213 3794, 515 S Flower Street, 4th Floor, Los Angeles, CA 90071
- Verizon Wireless (mobile phones): 611 (from each cellphone), various retail locations throughout Pasadena and/or any major city to which we could travel.
- Microsoft 365 (email hosting): 877 696 7786, One Microsoft Way, Redmond, WA 98052.
- Pasadena Department of Water and Power (utilities): 626 744 4005, 150 S Los Robles Ave, Suite 300 Pasadena, CA 91101.
We have contacted our bank to determine if they can continue to provide the financing that we will need in light of an internal or external SBD. The bank maintaining our operating account is Chase Bank, 860 E Colorado Blvd., Pasadena, CA 91101. Our contact persons are: Ms. La Rae Giammalva (626 795 0976) and Ms. Lorrina Garcia (626 536 2037).
We have no critical counterparties.
XII. Regulatory Reporting
Our firm is subject to regulation by the Broker-Dealer/Investment Advisor Division of the California Department of Business Oversight. We now file reports with our regulators electronically through FINRA. In the event of an SBD, we will check with the SEC, FINRA and/or the regulator to determine which means of filing are still available to us, and use the means closest in speed and form (written or oral) to our previous filing method. In the event that we cannot contact our regulators, we will continue to file required reports using the communication means available to us.
XIII. Disclosure of Business Continuity Plan
Attached is our written BCP disclosure statement. Inasmuch as clients open accounts at the custodian of their choice, we do not automatically provide this disclosure statement when those accounts are opened. That is the responsibility of the selected custodian. However, we post the disclosure statement on our website and mail it to customers upon request.
XIV. Updates and Annual Review
Our firm will update this plan whenever we have a material change to our operations, structure, business or location. In addition, our firm will review this BCP annually to modify it for any changes in our operations, structure, business or location.
XV. Senior Manager Approval
I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of an SBD.
Signed: Gregory J Welborn
Date: November 11, 2019