Integrated Financial Solutions Group Business Continuity Plan (BCP)

Updated January 1st, 2012

Overview

Integrated Financial Solutions Group LLC (IFSG) has developed a Business Continuity Plan ("BCP") as a contingency to mitigate any impact of possible future business interruptions.  Please read through this document carefully and become familiar with the alternatives we have in place to conduct business in the event of a Significant Business Disruption ("SBD").

IFSG's policy is to respond to a Significant Business Disruption by safeguarding employees' lives and IFSG property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of IFSG's books and records, and allowing our clients to transact business. In the event that we determine that we are unable to continue our business, we will assure clients prompt access to their funds and securities.

Contacting Us

Our office is located at 1820 Preston Park Blvd., Suite 1155, Plano, Texas  75093.  Our main office phone number is: (972) 312-1337

Emergency Contacts

Mark A. Trewitt at 214-405-4565 or 972-964-2144 or Glenn S. Martini at 972-489-1427

If after a significant business disruption you cannot contact us as you usually do, please go to our website at www.stopthewealthleakage.com where a notice will be posted with further instructions.

If you cannot reach us in either of these ways, you should contact our clearing firm, Sterne Agee or primary custodians First Trust Company of Onaga, Fidelity Investments (ITS), or Pershing (Hanlon) for the following transactions "ONLY": 

  1. Emergency Orders to liquidate (close) existing positions

  2. Emergency Instructions to issue a check or wire available funds

  3. Requests to ACAT (transfer) your account holdings  to another Broker/Dealer

Sterne Agee Corporate Headquarters            800-240-1438     www.sternagee.com

First Trust Company of Onaga                        800-521-9897     www.ftconaga.com

Fidelity Investments                                         800-544-9999 or 800-522-7297     www.fidelity.com

Pershing                                                            201-413-2000     www.pershing.com

Business Continuity Plan

Our Business Continuity Plan addresses data backup and recovery, all mission critical systems, financial and operational assessments; alternative communication with our clients, employees, regulators; alternative physical locations of employees, critical suppliers, contractors, banks and counterparty impact; regulatory reporting and assuring clients of prompt access to their funds and securities if we are unable to continue business due to an SBD.

Our clearing firm, Sterne, Agee, backs up its important records in a geographically separate area.  You may contact them directly at 800-240-1438.

Disclaimer

Our firm's BCP is designed to meet our existing obligations to clients in the event of an emergency or significant business disruption; however, it is not infallible. The unpredictable nature of some events may make it impossible to anticipate every scenario that could cause a business disruption.

Although we are confident in our own preparedness, IFSG LLC has no control over the third party entities that we must rely upon in the event of an emergency.  We test our Business Continuity Plan from time to time to ensure our readiness; yet these tests may not replicate conditions we would experience in a real emergency.

Our BCP is subject to change without notice and we will maintain the most current Plan on our website at www.stopthewealthleakage.com. This is provided to you for informational purposes only.

Objectives of the Business Continuity Plan

  1. Reduce confusion by giving a clearly defined course of action, and thus providing for an orderly and timely recovery
  2. Identify personnel, resources, and the functions necessary for continued operation in the event of disruption
  3. Provide appropriate client communications
  4. Minimize the impact to IFSG’s public and industry image
  5. Define alternate procedures for ongoing operation of critical functions
  6. Identify the locations to be used to continue operations in the event of a disruption
  7. Use an established plan to resume normal operation, within redefined limits, after a disruption

Significant Business Disruptions

Our plan anticipates two types of SBD's:  Internal and External.  Internal SBD's are interruptions that deny access to our facilities or resources such as a fire, flood, power outage or hazardous material incident.  External SBD's prevent the operation of the securities markets or a number of firms, such as a terrorist attack or a wide-scale, regional disruption.  With either type of disruption, if our critical Information Technology systems are disrupted, we will have to rely on our key third party processors, vendors, suppliers and financial institutions.  Whether the disruption is internal or external, IFSG's plan is designed to recover our business functionality within twenty-four (24) hours and process all outstanding business.

Rule: FINRA Rule 4370(e) Approval and Execution Authority

Glenn S. Martini, Registered Principal, IFSG Compliance Officer and Vice President/Chief Compliance Officer for VFG Securities, is responsible for approving the plan and for conducting the required annual review.  Mr. Martini can be reached at 972-312-1337 or This e-mail address is being protected from spambots. You need JavaScript enabled to view it .  Mr. Martini also has the authority to execute this BCP.

Rule: FINRA Rule 4370(d) - Business Description

IFSG is a full-service financial planning firm.  Our expertise includes alternative investments, insurance, estate planning, retirement planning, and traditional publicly traded investments.

Our firm is an introducing firm and does not perform any type of clearing function for itself or others. Furthermore, we do not hold customer funds or securities. We accept and enter orders.  All publicly traded securities transactions (excluding Managed Accounts) are sent to our clearing firm, which executes our orders, compares them, allocates them, clears and settles them where applicable.  Our clearing firm also maintains certain customers’ accounts, can grant customers access to them, and delivers funds and securities. Our firm services only retail customers.  We engage in Alternative Investments and Private Placements.

Our clearing firm is Sterne Agee.  Our clearing firm has given us a contact number of 800-240-1438.

Alternative Physical Location(s) of Employees

IFSG maintains a single business office in Plano, Texas.  Depending on the severity and duration of a SBD, IFSG has plans to transfer employees to locally available office space or executive suites.  We have determined that in the event of a significant business disruption, we must initially resume business by having an Initial Response Team functioning within the first twenty-four (24) hours after the event to process that day's business.

Information Technology (IT) Alternative Processing Site

IFSG has developed and equipped a disaster recovery site located in Plano, Texas.  This location will house equipment allowing the following backup and operational capabilities:

Cloud-Based Computing Services:

  • SmartOffice Client Data
  • ConstantContact Email System
  • Simplicato Compliance System
  • DST Vision

IFSG Server Mirror Backup

Internet Access to Stern Agee and First Trust Company of Onaga

Internet Access to All Product Sponsors and Websites

Should the severity of the disruption dictate that the offices at 1820 Preston Park Blvd. be inoperable for an extended period of time, the IFSG Initial Response Team is prepared to integrate all existing employees and phone systems through an alternate physical location in Plano, Texas.

Operations Response

Management of the Operations team has determined that they will designate four (4) persons to the Initial Response Team to process business transactions and customer service requests at the Disaster Recovery Site in the event of a disruption at 1820 Preston Park Blvd.  Four (4) workstations at the Disaster Recovery site will be setup to mirror the functionality of these employees, to give them immediate access to all necessary functions.  If the duration of the disruption exceeds twenty-four (24) hours, additional workstations will be setup for remaining personnel.  If it is determined that the disruption should exceed seventy-two (72) hours, IFSG management will deploy their remaining personnel at the Disaster Recovery Site.

Trading Response

If the event reaches a certain level of severity and duration, or if the Preston Park office is totally shut down, management at the Disaster Recovery Site will direct all trading efforts as required.

Rule: FINRA Rule 4370(c)(6) - Clients' Access to Funds and Securities

In the event of a SBD wherein IFSG operations is caused to relocate to an alternate site, clients will have uninterrupted access to their funds by identifying balances via internet access, contacting their introducing broker dealer or telephoning the IFSG operations center location. (See numbers below.)

IFSG Main: 972-312-1337

VFG Securities Main: 1-800-737-8552

Clients may withdraw funds from their accounts by contacting Fidelity/ITS, Pershing/Hanlon, Sterne Agee or First Trust Company of Onaga directly or through their introducing broker dealer requesting that a wire or check be sent to their bank or address of record.

In the event that a disaster of such magnitude mandates the discontinuance of operations, IFSG would perform an orderly discontinuance of business under its present BCP, properly notify regulatory authorities including the Securities Investor Protection Corporation (SIPC), the Financial Industry Regulatory Authority (FINRA), the Securities and Exchange Commission (SEC), and the Texas Department of Insurance (TDI).

Rule: FINRA 4370(c)(10); Securities Exchange Act Rule 15c3-1; 15 U.S.C. 78eee - Data Back-Up and Recovery (Hard Copy and Electronic)

IFSG provides off-site storage of the company's electronic data back-up files.  Data from our server is copied to mirror disk drives at a remote location.   We perform a daily backup of our Preston Park office server and store it offsite.  The offsite facility is located in Plano, Texas, providing an acceptable geographic distance from IFSG's main office location.

In addition, the following 3rd-party systems provide secondary backup of client information and records via the Internet:

  1. SmartOffice Client Data
  2. ConstantContact Email System
  3. Simplicato Compliance System
  4. DST Vision
  5. Stern Agee and First Trust Company of Onaga
  6. All Product Sponsors and Websites

IFSG ensures that all firm documentation not covered above (such as employee records, administrative contracts and system generated reports for reconciliation, etc.) is scanned for archiving on IFSG's mirror drive system. The documents are then backed up as described in the first paragraph.

Rule: FINRA Rule 4370(c)(1) - Financial and Operational Assessments

Operational, Financial and Credit Risk

Operational risk focuses on IFSG's ability to maintain communications with clients and to retrieve key activity records through its "mission critical systems."  IFSG has fully documented our communication capabilities and has procedures in place to notify our clients of all available means of communication. Financial risk relates to IFSG's ability to continue to generate revenue, and obtain new or retain adequate financing and sufficient equity.  IFSG may experience operating losses during a SBD of extended duration.  Such losses are mitigated by the following:

  1. Business Interruption Indemnity Insurance
  2. Recurring Revenues from Actively Managed Investments
  3. Financial Reserves with Operating Entities
  4. Lines of Credit with Various Financial Institutions

These financial reserves will assist in financing operations in the event of a significant business disruption.

Rule: FINRA Rule 4370(c)(3) - Mission Critical Systems

IFSG’s "mission critical systems" are those that ensure prompt and accurate processing of securities transactions, including completion of New Account Forms, Transfers, Change Requests, maintenance of client accounts, and access to client accounts.  We have identified the following functions as critical to our daily business and will be supported during a SBD.

Order Taking/Order Entry – IFSG New Business Desk provides the mechanism for order entry from our location.

Trading – Mutual Funds/Equities - IFSG New Business Desk provides the mechanism for liquidation of mutual fund positions from our location.

Execution - order acceptance and routing of orders to an executing agent will be virtually uninterrupted by use of Internet access, telephone and fax transmission capability.  IFSG's BCP envisions remote switching of incoming communication lines to any alternate location in the event of an interruption at their present location.

Access to Client Accounts - IFSG maintains all client accounts and records on our office server and the alternate site, also in Plano, Texas.  Access is via the Internet.  Books and Records reports are stored in both locations.

Rule: FINRA Rule 4370(c)(2)) - Alternate Communications Between IFSG and Clients, Employees, and Regulators

Clients

IFSG maintains our primary business office and home office in Plano, Texas. If a SBD occurs either locations, all calls into that location, or locations, will be re-routed to the functioning office or managing partner’s cellular or home office phone in order to best serve the client's needs.  If all local telecommunications are inoperative, then clients can call  VFG Securities at 1-800-737-8552 for service. Information will be posted on IFSG’s website to keep our clients informed of all available means to communicate with IFSG and alternate phone numbers to transact business.

Employees

IFSG utilizes an internal emergency contact system to allow management immediate capabilities in communicating quickly, accurately and efficiently with all employees to disseminate information and to determine their immediate well being.  An internal phone tree exists for Employees to contact IFSG Management as required.

Regulators

The Compliance area of IFSG has the responsibility to notify and communicate with the Regulators upon the occurrence of a SBD. This communication would be by telephone, cell phone, and fax or through the Internet. The Compliance Officer will continue to keep the Regulators apprised of our SBD.

Rule: FINRA Rule 4370(c)(4)(5)(9) - Critical Business Constituents, Banks, and Counter-Parties

We have contacted our critical business constituents and determined the extent to which we can continue our business relationships with them in the event of a significant business disruption. We will quickly establish alternative arrangements if one of these entities can no longer provide the needed goods or services when we need them because of a SBD to them or our Firm. IFSG will continue to evaluate our business partners to ensure that we have the flexibility, in the event of a SBD, to service our client's needs.

Rule: FINRA Rule 4370(c)(7) - Regulatory Reporting

IFSG is subject to regulation by multiple regulatory bodies. We now file reports with our regulators using paper copies in the U.S. mail and electronically using fax, e-mail and the Internet. 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 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.

Rule: FINRA Rule 4370(c)(8) - Disclosure of Business Continuity Plan

IFSG posts our BCP disclosure statement on our web site, www.stopthewealthleakage.com.  If additional copies are needed or if clients have questions regarding IFSG’s BCP, they should contact Compliance Officer Glenn Martini at 972-312-1337 or at This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

Rule: FINRA Rule 4370(e) - Updates and Annual Review

The IFSG Business Continuity Plan will be updated whenever we have a material change to our operations, structure, business or locations. IFSG’s Compliance Officer will audit the plan approximately every eighteen (18) months; while Managing Partners will review IFSG's plan annually, on or near October 1st, and will modify it if necessary. All changes made to the plan will be communicated to the affected parties, and any changes will be reported to the appropriate regulatory bodies.

Rule: FINRA Rule 4370(d) - Senior Management 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:  Mark A. Trewitt

Title:      Managing Partner

Date:     January 1st, 2012

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