Quick Reference
Emergency Contacts
Technology Support
Envoy Managed Services
Phone: (817) 349-2155
Mobile: (817) 89X-XXXX
1000 Texan Trail, Suite 155
Grapevine, TX 76051
Web: envoymanagedservices.com
Email: help@envoymanagedservices.com
Internet Providers and VoIP Providers
Dallas, TX
AT&T
Ridgeland, MS
Fuse.Cloud
https://fuse.cloud/contact-us/
(601) 643-9769
St. Louis Park, MN
Comcast/Xfinity
https://corporate.comcast.com/
(800) 934-6489 (1-800-XFINITY)
Watertown, SD
Midcontinent Communications
https://www.midco.com/
(800) 888-1300
Bettendorf, IA
Central Scott Communications
https://centralscott.com/
(563) 285-9611
Sioux Falls, SD
SDN Communications
https://sdncommunications.com/
(800) 247-1442
Building & Facilities Managers
Bettendorf, IA
Northwest Bank & Trust Company
100 E. Kimberly Road
Davenport, Iowa 52806
(563) 388-2500
northwestbank.com
St. Louis Park, MN
Jordan Palmstein HME Properties
jordan.palmstein@bwbmn.com
4450 Excelsior Blvd., Suite 100
St. Louis Park, MN 55416
(952) 893-6868 (Office)
Watertown, SD
Tony Brallier
Dallas, TX
Shorenstein – Michelle Martin
Tenant Services Administrator
(972) 450-8105
mmartin@shorestein.com
Sioux Falls, SD
Cornerstone Bank
Terry Cleberg, SVP
(605) 305-3399 or 605-20X-XXXX
terry.cleberg@cornerstonebanks.com
Ridgeland, MS
SCHorn Properties
Steve Horn
stevehhorn@gmail.com
601-57X-XXXX
Banking
B1 Bank
(877) 614-7600
2401 Cedar Springs Road, Ste. 420
Dallas, TX 75201
Multiple locations in Southeastern United States (Dallas)
https://www.b1bank.com/
Sunflower Bank
(888) 827-5564
8117 Preston Road
Dallas, TX 75225
CustomerService@SunflowerBank.com
Data Backup & Recovery
ShareFile
https://support.sharefile.com/s/
(800) 441-3453
Practifi
Practifi Success
oscar.husselbee@practifi.com
312-31X-XXXX
Andersen (Accounting)
5420 LBJ Freeway, Suite 410
Lincoln Centre Two
Dallas, TX 75240
edwin.roberts@andersen.com
(Tel) (972) 755-4735
(Cell) 214.70X.XXXX
andersen.com
Orion Technology
Ron Pruitt, President
ron@orion.com
Orion.com
214-73X-XXXX
Custodian(s) & Broker/Dealers
Schwab Institutional
Alynn Eubanks, Relationship Manager
3000 Schwab Way
Westlake, TX 76262
https://advisorservices.schwab.com/
Tel: (972) 731-2733
Cell: (469) 3XX-XXXX
Principal
(800) 547-7754
principal.com/welcome
American Funds
capitalgroup.com/ria
(800) 421-5450
Fidelity
SEI
(610) 676-1000
https://www.seic.com/contact-us
Empower
(800) 338-4015
participant.empower-retirement.com
Lionstreet Financial (BD)
Newport/Ascensus
newportgroup.com/login/participant
(844) 749-9981
AssetMark
Jason Nagel
(925) 52X-XXXX
John Hancock
myplan.johnhancock.com/login
(800) 294-3575
1. Introduction
Balefire, LLC (CRD#168733) (“Balefire”) is an Investment Advisor registered with the US Securities and Exchange Commission (“SEC”). As such, to ensure that we can provide ongoing and continuous service to our clients, Balefire has adopted and implemented this written business continuity and transition (collectively, the “BCP”). This manual documents the BCP supporting the recovery of our critical business functions and systems in the event of a business disruption.
Balefire has intentionally and strategically adopted an internet and cloud-based platform so the firm can perform its critical functions and support its clients from any physical location with access to the internet and cellphone services. Balefire is also geographically dispersed which significantly decreases the potential for its capabilities to be adversely impacted by regional events caused by weather, man-made disasters, or Acts of God.
2. Emergency Contact Persons – BCP Call Tree
The following Primary and Secondary Emergency Contacts have been designated by the Executive Committee of Balefire:
| Primary | Secondary | ||
|---|---|---|---|
| John Hoffman | (612) 31X-XXXX | Mark Oswald* | (414) 53X-XXXX |
| Stephanie Elton** | (303) 90X-XXXX | ||
| Robin DeHoyos*** | (806) 23X-XXXX | ||
| Jason Hester | (601) 42X-XXXX | Chris Tipton* | (601) 21X-XXXX |
| Amber Rogers** | (601) 94X-XXXX | ||
| Charlene Smith*** | (601) 25X-XXXX | ||
| * 1st Alternate Primary | |||
| ** 2nd Alternate Primary | |||
| *** 3rd Alternate Primary |
Only either of the Primary Emergency Contact, or in their mutual absence or incapacitation the successive alternates, are empowered to enact the BCP. Once enacted, the initial step is to communicate to all Balefire associates the condition that caused the BCP to be triggered, the status of the facilities and functionality of critical locations, where and to who associates should report or contact, how critical business functions should be conducted, and instructions for future steps to be taken by the associate.
Balefire has adopted and periodically amends the BCP Call Tree attached as Exhibit A to facilitate organized communication. The BCP Call Tree is distributed to all Balefire associates tasked with contacting other associates in the event the BCP is enacted. A copy is maintained in the BCP folder in ShareFile and is available to all associates on the Balefire intranet.
3. General Considerations and Purpose of the BCP
Balefire’s intention is to respond to any significant event by safeguarding lives and our property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of our
books and records, and allowing our clients to communicate with us and conduct business.
4. Significant Business Disruptions (SBD)
Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect one or more business functions typically limited to a single location, such as a power outage, cyberattack, fire, or loss of internet.
External SBDs prevent the operation of the securities markets or multiple business functions and locations, such as a terrorist attack, a city flood, or a wide-scale, regional, or national disruption.
5. Primary Business Constituents, Custodians, and Counterparties
In the event the BCP is enacted due to an SBD it is important for our clients to be able to contact their account custodians directly should they not be able to contact Balefire. In the event of an SBD, we will
post these numbers to our website, as available and appropriate, or otherwise use email, US mail, SMS, social media, and phone calls to communicate this information to our clients.
Retail Clients
- Schwab Institutional (877) 519-1403
- American Funds (800) 421-4225
- SEI Investments Company (800) 342-5734
- AssetMark (800) 664-5345
Institutional Clients – Qualified Plans
- Fidelity (800) 347-2673
- Empower (800) 338-4015
- Newport/Ascensus (844) 749-9981
- John Hancock (800) 294-3575
Broker/Dealer Clients and NQ Deferred Compensation Plans
- Lionstreet Financial Services (512) 776-8400
Insurance Clients
- Lion Street Inc. (512) 776-8400 (Fixed Life)
- Advisors Excel (866) 363-9595 (Fixed Annuity)
6. Approval and Execution Authority
John Hoffman and Jason Hester, Managing Partners, are responsible for approving the BCP and for reviewing it annually. John Hoffman, Jason Hester, and Mark Oswald, along with Stephanie Elton and Robin DeHoyos have the authority to execute the BCP.
7. Plan Location and Access
Each Balefire Office will maintain a physical copy of the BCP, and an electronic copy of each version will be maintained in ShareFile. Each Balefire associate will be emailed a copy of the current BCP upon its
adoption.
8. Business Description
Balefire conducts business and provides services to Private Wealth, Qualified Retirement Plans, Non-qualified Deferred Compensation Plans, Insurance, and broker/dealer clients. We accept and enter orders and service retail and institutional accounts.
9. Client Access to Funds and Securities
All custodial, cashiering, and clearing operations are conducted by third parties identified in this BCP who hold customer funds and securities on our behalf (“Qualified Custodians”). All transactions and service
requests are sent to a Qualified Custodian who executes our orders, compares them, allocates them, clears and settles them. Qualified Custodians also perform all cashiering functions and delivers funds and securities. See Section 5; Primary Business Constituents, Custodians, and Counterparties.
10. Mission Critical Systems
Mission critical systems are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities
transactions, the maintenance of customer accounts, access to customer accounts and the delivery of funds and securities.
We have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions. Our Qualified Custodians provide clearing, execution, delivery, payment, cashiering, and similar functions for the benefit of our clients. In the event of SBD, the most critical functions are establishing communication with our clients, our associates, our Qualified Custodians, and our regulators.
Order Taking
Currently, we receive orders from customers via telephone, or in person. During an SBD, either internal or external, we will continue to take orders through any secured and verified method that is available and
reliable, and in addition, as communications permit, we will inform our customers to tell them what alternatives they have to trade or access funds and securities. If clients are unable to reach us, they will
be directed how to contact their Qualified Custodian directly. See Section 5: Primary Business Constituents, Custodians, and Counterparties.
Order Entry and Order Execution
Our orders can be entered electronically, cell phone, or VoIP capabilities utilizing Orion, advisorservices.com, through AssetMark, Fidelity, or other platforms available directly from our Qualified Custodians. A list of contacts for our Qualified Custodians can be found in this BCP (See Section 5). We will pivot to the platform and means of communication which allow us the fastest alternative means available. We will also advise affected clients that they may contact their Qualified Custodian directly and provide them with contact information. Order execution is provided by our Qualified Custodians.
11. Financial and Operational Assessments
A. Operational
In the event of a SBD at one or more Balefire location, the COO, his or her delegate(s), and Team Directors are responsible for conducting an assessment of Mission Critical Systems and capabilities at each location. Each assessment will be communicated to the COO who will, in turn, communicate systems capabilities to the Managing Partners.
Balefire will assess its access books and records and access cloud-based backup records from its various native redundant backup platforms. See Section 12: Data Back-up and Recovery.
In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter parties and regulators. Typically, these would include email, social media, VoIP capabilities, and cell phones. If needed, we will direct clients to the Custodians and counterparties detailed in Section 5: Primary Business Constituents, Custodians, and Counterparties section of this BCP.
B. Financial and Credit
In the event of an SBD, the COO is responsible to assess the financial condition of Balefire, and its access to funds and capital, to determine our ability to continue to fund our operations for the benefit of our clients. If we determine that we may be unable to meet our obligations to those counterparties or otherwise continue to fund our operations, we will request additional financing from our bank, owner/partners, or other credit sources to fulfill our obligations to our customers and clients. If we cannot remedy a capital deficiency, we will file appropriate notices with our regulators and immediately take the appropriate steps.
12. Data Back-up and Recovery (Hard Copy and Electronic)
Balefire does not maintain hard copies of its books and records. The records required by the Investment Advisers Act of 1940, as amended (the “Act”) are maintained electronically and backed up nightly to cloud-based systems including Microsoft, ShareFile/Citrix, Sage, Schwab, AssetMark, Fidelity,
Practifi/SalesForce, Orion, and DocuSign. Native redundancies exist in each of these platforms to ensure that proper records are maintained and backed up nightly. In the event of a loss of access to electronically store books and records due to a SBD, we will establish temporary hardcopy records and recover the storage media over the internet from an alternate Balefire location.
The CCO, or his delegate, is responsible for the maintenance and recovery of these books and records. Balefire maintains books and records for its internal operations, Registered Investment Advisor, Lionstreet Financial Services brokerage, insurance, Corporate Solutions, and Financial Planning enterprises.
13. Alternate Communications with Clients and Fuse
We communicate with our clients using the telephone (VoIP), email, our website, U.S. mail, and during in-person visits at our offices. 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. In some cases, where facilities are unavailable and associates are asked to work-from-home or from other alternate locations, we will direct associates to use personal devices such as cell phones, and email from a professional domain or social media platform captured by Global Relay (email, LinkedIn, Slack, Facebook Messenger) using whatever means of communication available to us.
14. Alternate Communication between Balefire and Balefire Associates
We communicate with our employees using telephone, email, cell phones, electronic communication, Slack, and in person. 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. We will also employ a call tree so that senior management can reach all employees quickly during an SBD. (See: Exhibit A)
15. Alternate Physical Location of Fuse Associates
In the event of an SBD, we may move associates from affected office(s) to the closest of our unaffected office location(s), depending on the anticipated duration of the interruption. The more likely solution will be to send associates to their homes or a temporary business facilities solution with internet access and communication capabilities. Balefire has tested and is satisfied that it can operate effectively to the benefit of its clients from geographically disperse locations and a work-from-home environment.
16. Regulatory Reporting & Communication with Regulators
We have the capability to communicate with our regulators using telephone, email, cell phones, the internet, fax, U.S. mail, and in person. 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 regulator.
Regulatory Reporting
We are subject to regulation by the SEC, FINRA, and the various States where we are registered or Notice Filed. We now file reports with our regulators electronically using the IARD/CRD, FinPro, and EDGAR. In the event of an SBD, we will check with the SEC, FINRA and other regulators 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.
State of Texas
Phone: (512) 305-8633 or Fax: (512) 305-8310
208 East 10th Street
Austin, TX 78701
NASAA
FINRA
District 6 – Dallas
12801 North Central Expressway, Suite 1050
Dallas, TX 75243-1778
Phone: (972) 701-8554
Fax: (972) 716-7646
finra.org
SEC
Fort Worth Regional Office
Burnett Plaza
801 Cherry Street
Suite 1900, Unit 18
Fort Worth, TX 76102
(817) 978-3821
dfw@sec.gov
17. Disclosure of Business Continuity Plan
The BCP summary is posted to our website at balefirewealth.com and mailed to clients, free of charge, upon request.
18. Updates and Annual Review
We will update this plan whenever we have a material change to our operations, structure, business, location, or any other change that could impact our ability to provide timely services to our clients or meet our existing obligations. In addition, the CCO will review this BCP annually and make modifications as necessary in light of changes to our operations, structure, business, or location.
I have approved this Business Continuity Plan as reasonably designed to enable Balefire, LLC to meet its obligations to customers in the event of an SBD.
John Hoffman, Managing Partner
Date
Jason Hester, Managing Partner
Date
Exhibit A
John Hoffman Calls
Jim Mars > Calls Finance Team
Jason Hester
Mark Oswald
Chad Slotta
Blair Enfield > Calls M&A Team
Stephanie Elton > Calls Back Office Team
Robin DeHoyos
Jason Hester Calls
Charlene Smith > Calls Erin Ovre > Calls Client Engagement Team
Travis Bush > Calls Wealth Advisory Team
Michael Rabiner > Calls Investment Team
Pete Peterson > Calls Corporate Solutions Team
Erika Wood > Calls Planning Team
Steven Rutledge > Calls Insurance Team
Chris Tipton