1. PREFACE
Despite efforts by businesses, state and local governments, and federal agencies to renovate, validate, and implement mission-critical information systems, the financial industry remains vulnerable to disruptions in its business processes. Because most companies in the financial industry depend heavily on information technology to carry out their business, a business disruption-induced failure of one or more mission-critical systems may severely impact a financial services firm’s ability to deliver core business services. Because of these risks, the United States Securities and Exchange Commission (“SEC”) has implemented programs to mitigate the risks of business failures in the financial industry caused by a significant business disruption that prevents the delivery of financial services. Specifically, the SEC requires firms to create and maintain business continuity plans. Ultimately, the business continuity planning process focuses on reducing the risk of business failures resulting from business disruptions. It safeguards a company's ability to produce a minimum acceptable level of output and services in the event of failures of internal or external mission-critical information systems and services. While it does not offer a long-term solution to all situations that create a significant business disruption, it will help Stride Wealth LLC prepare for a potential crisis.
2. REGULATORY BACKGROUND
2.1. General Overview
Based upon regulations and rules implemented by the SEC and other state securities regulators (collectively “Regulators”), and being held to the fiduciary standard, investment advisers are required to protect their clients’ interests from being placed at risk as a result of the adviser’s inability to provide financial services after a disaster, death of key personnel, or other interruption of business. Additionally, this business continuity plan is intended to address our obligation as an investment adviser to establish and maintain procedures to safeguard our records against destruction or loss.
2.2. Plan Elements.
The Business Continuity Plan (the “Plan”) for Stride Wealth LLC (referred to herein as the “Stride Wealth,” “Company,” “our,” “us,” or “we”) addresses the 10 critical elements listed below:
- Data backup and recovery (hard copy and electronic).
- All mission-critical systems.
- Financial and operational assessments.
- Alternate communications between clients and Stride Wealth.
- Alternate communications between Stride Wealth and its employees, supervised persons, and independent contractors providing clerical and advisory support to our clients (collectively, “supervised persons”).
- Alternate physical location of employees.
- Critical business constituents, banks, and counterparty impact.
- Regulatory reporting.
- Communications with regulators; and
- How Stride Wealth will ensure clients’ prompt access to their funds and securities if Stride Wealth determines that it is unable to continue its business.
3. PLAN OVERVIEW
3.1. Company Policy
The policy of the Company is to respond to a Significant Business Disruption (“SBD”) by safeguarding employees’ lives and Company property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the Company’s books and records, and, to the extent practicable, allowing our clients to transact business as soon as possible following an SBD. If the Company determines it is unable to continue its business, Stride Wealth will take steps to ensure clients have prompt access to investments and the underlying issuers of those investments.
3.1.1. Significant Business Disruptions
The Plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the Company's ability to communicate and conduct business, such as a fire in its building. External SBDs prevent the operation of the securities markets or of a number of firms, such as due to a terrorist attack, a city flood, or a wide-scale regional disruption. The Company's response to an external SBD relies more heavily on other organizations and systems.
3.1.2. BCP Designated Principal - Approval and Execution Authority
Tanner Erickson (the “BCP Designated Principal”) is the registered and designated principal responsible for approving the Plan on behalf of Stride Wealth, and for conducting the required annual review and testing. The BCP Designated Principal has the authority to execute this Plan.
3.1.3. Plan Location and Access
The Company will maintain copies of the Plan, the annual reviews, and any changes made to it. The Firm will make such records available for inspection by the Regulators. An electronic copy of the Plan is located on the Company’s computer and/or in a folder named “Business Continuity Plan.”
3.1.4. Updates and Annual Review
The Company will update the Plan whenever there is a material change to the operations, structure, business, or location of Stride Wealth. In addition, the Company will review this Plan annually, on or before 12/31 of each respective year, to modify it for any changes in the operations, structure, business, or location of Stride Wealth.
3.2. Emergency Contact Person
Executive management is aware of the potentially devastating financial, organizational, and political consequences of the failure of one or more mission-critical information systems. The emergency contact person for the Company is: Tanner Erickson, Managing Member, CCO Office phone number: 480-349-7085 E-mail address: tanner@stridewealthgroup.com
3.3. Business Description
Stride Wealth is registered with the state of Arizona as an investment adviser, and various other state regulatory jurisdictions, as necessary. Stride Wealth provides investment advisory services and financial planning services to its clients. These services include recommending investments based on clients’ needs, risk tolerance, and other client assets and obligations. The Company is organized as a Limited Liability Company.
3.4. Office Location
Stride Wealth has set forth the main office on Attachment A, which is attached hereto and incorporated herein for all purposes. The Company has additionally outlined in Attachment A the phone number for each respective location, the means of transportation that the supervised person may use to reach each respective facility, and the systems, as defined herein, that take place at each location.
3.5. Alternative Physical Location(s)
In the event of an SBD, we will move our supervised personnel to an unaffected location or have them work from home. Staff will use their cell phones, company laptops, tablets, and personal computers for contact purposes.
4. CUSTOMERS’ ACCESS TO FUNDS AND SECURITIES
The Company does not maintain physical possession or custody of clients’ funds or securities. Both client funds and securities are maintained by Charles Schwab & Co., Inc. (“Custodian”), or the investment entity where such client invested their funds. In the event of an internal or external SBD, if telephone service is available, our supervised persons will continue to manage client portfolios, and receive client orders or instructions and, to the extent practicable, assist such clients in contacting the issuers of the securities on their behalf. If clients of the Company are unable to access Stride Wealth, either at its primary phone number or Stride Wealth emergency number, clients will be able to contact their Custodian and/or the respective issuers of securities directly for instructions on how they may obtain prompt access to funds and securities, subject, however, to any limitations set forth previously by such Custodian and/or the issuers of investment products.
5. DATA BACK-UP AND RECOVERY
5.1. Electronic and Hard Copy Books and Records
The Company maintains a backup of its primary hard-copy books and records, as well as its electronic records, at 1425 S. Higley Road, Suite 106, Gilbert, AZ 85296. Tanner Erickson is responsible for the maintenance of these books and records. The Firm maintains the following document types: (i) new account documentation and forms; (ii) client confirmations and account statements; (iii) financial records, including supporting documentation; and (iv) corporate records for Stride Wealth.
5.2. Back-up Procedures
The Company maintains its backup hard-copy books and records either online, by producing a second paper copy, or by backing up to an external hard drive.
5.2.1. Electronic Records
The Company has contracted the services of Datatek LLC to perform daily automatic secure online backups of its electronic records. The data is backed up on a cloud server.
6. FINANCIAL AND OPERATIONAL ASSESSMENTS
6.1. Operational Risk
In the event of an SBD, the Company will immediately identify what means will permit Stride Wealth to communicate with its clients, supervised persons, critical business constituents, critical banks, critical counterparties, and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will generally include (a) facsimile; (b) email; (c) telephone; (d) telephone voicemail; (e) cellular and mobile phone service; (f) service providers, including compliance consultants, attorneys and accountants; (g) messenger; and (h) mail service. In addition, we will retrieve our key activity records as described in the section Data Back-Up and Recovery.
6.2. Financial and Credit Risk
In the event of an SBD, the Company will determine whether the business interruption causes the Company to become capital deficient or to interrupt its operations to the point that the alternative measures discussed in the sections above and below cannot be implemented. The Company’s clients shall be referred to the Custodian.
7. MISSION CRITICAL SYSTEMS
7.1. Mission Critical Systems - Definition
"Mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, the maintenance of client accounts, access to client accounts, and the delivery of funds and securities.
7.2. Identify Business Systems
The Company will identify the mission-critical systems used by Stride Wealth to provide advisory services to its clients.
7.3. Mission Critical Systems - Assessment
The Company is primarily responsible for establishing and maintaining its business relationships with clients. It is solely responsible for maintaining its mission-critical functions of client portfolio management, order taking, and entry. Its mission-critical systems include desktop and laptop computers and phone systems.
7.4. Mission Critical Systems Provided by Our Custodian
Our Company relies, by contract, on Custodian to provide order execution, order comparison, order allocation, client account maintenance and/or access and delivery of funds and securities.
8. ALTERNATIVE COMMUNICATIONS BETWEEN FIRM AND CLIENTS, EMPLOYEES AND REGULATORS
8.1. Clients
Stride Wealth currently communicates with our clients using the telephone, email, U.S. mail, delivery services, and in-person visits at our offices or at the client’s location. In the event of an SBD, Stride Wealth will assess which means of communication are still available to it, and use the means closest in speed and form, either written or oral, to the means that have been used in the past to communicate with the other party. For example, if the Company has communicated with a party by email but the internet is unavailable, Stride Wealth will call them by telephone and, where a record is needed, follow up with a paper copy sent by U.S. mail.
8.2. Employees and Supervised Persons
The Company now communicates with its employees and supervised persons using the telephone, email, and in person. In the event of an SBD, Stride Wealth will assess which means of communication are still available, and use the means closest in speed and form, either written or oral, to the means that have been used in the past to communicate with the other party. A copy of the corporate telephone directory, including home phone numbers and email addresses, is attached hereto as Attachment B. Tanner Erickson shall contact and communicate with all employees and supervised persons by telephone, email, messenger, or in person.
8.3. Regulators & Regulatory Reporting
With respect to regulatory reporting, we currently file reports with the respective Regulators using paper copies via the U.S. mail and delivery services, electronically via facsimile, email, and the internet, and through service providers that provide access via the same methods. In the event of an SBD, Stride Wealth will check with the Regulators to determine which means of filing are still available to it and use the means closest in speed and form (written or oral) to the previous filing method utilized by the Company. If the Company cannot contact its Regulators, it will continue to file required reports using the communication means available
to Stride Wealth. Contact information regarding the Regulators with whom Stride Wealth files reports on a regular basis attached hereto as Attachment C.
9. CRITICAL BUSINESS CONSTITUENTS, BANKS, AND COUNTER-PARTIES
9.1. Business Constituents
The Company has contacted its critical business constituents (businesses with which Stride Wealth has an ongoing commercial relationship in support of its operating activities, such as vendors providing us critical services) and determined the extent to which Stride Wealth can continue its business relationship with them considering the internal or external SBD. The Company will quickly establish alternative arrangements if a business constituent can no longer provide the goods or services needed because of an SBD to them or Stride Wealth. The Critical Business Constituents are set out on Attachment D, including the supplier’s name, service and/or product, address and phone number, and any alternative supplier’s name, service, address, and phone number.
9.2. Counter-Parties
The Company has contacted its critical counterparties, such as other broker-dealers, companies or entities offering investment products, or institutional clients, to determine whether it can carry out its transactions with them in light of internal or external SBD. Where transactions cannot be completed, Stride Wealth will contact those counterparties directly to make alternative arrangements to complete them as soon as possible.
10. SIGNIFICANT BUSINESS DISRUPTIONS
10.1. Cybersecurity and Identity Theft
Stride Wealth has adopted comprehensive written policies and procedures addressing both physical security and cybersecurity (“Cybersecurity Policies and Protocols”) to protect the confidentiality, integrity, and availability of client and firm records. These protocols are specifically designed to align with the nature of our advisory business and include measures to: (i) protect client records and information from reasonably foreseeable threats or hazards; (ii) implement safeguards to maintain the confidentiality of client data; and (iii) prevent the unauthorized disclosure of any information that could potentially cause harm or inconvenience to clients. Our Cybersecurity Policies and Protocols are detailed in Section 4 of our Compliance Manual, titled Privacy, Data Protection, Cybersecurity, and Identity Theft, and are incorporated herein by reference for all purposes.
10.2. Internal SBD – Facilities Emergency Evacuation Procedures
10.2.1. Fire Emergency Evacuation Procedures
If an evacuation of any facility is necessary, follow the directions given by Tanner Erickson, the designated Fire Marshal for the Company. If evacuation of the space is necessary due to fire, when the fire alarm bells sound continuously, employees should evacuate the building via the nearest available fire exit. As always, if you see or smell smoke, you should proceed to one of the other fire exits. Remember, if you have visitors or contractors with you, instruct them to follow you.
10.2.2. Evacuation for Bombs or Other Threats
If the Company has to evacuate the building facilities because of a bomb or any other threat, we will receive instructions from the building security coordinator to evacuate the building by an exit route that will be announced if instructions are given to evacuate. Remember, if you have visitors or contractors with you, instruct them to follow you.
10.3. Emergency during Business Hours
All Company personnel should follow the standard emergency evacuation procedures outlined above. Further instructions will be given at the designated Assembly Point.
10.4. Emergency Outside of Business Hours
In an emergency involving any employee’s personal safety, every employee must check in and report their whereabouts. You should leave a voicemail on one of the following phone lines: Tanner Erickson Home/Cell Phone: 480-349-7085 Office phone: 480-349-7085 When leaving your initial message, please include the following information: • • • •
Your name. Your contact number. Where you are physically. Whether you have access to your voicemail and email.
10.5. Pandemic Recovery Outline
Our mission is to protect staff from the impact of a pandemic illness, ensure information system uptime, data integrity and availability, and overall business resilience. To achieve this mission, Stride Wealth will seek to minimize the risk of infection and the transmission of communicable diseases, including those that pose a credible threat of transmission, in the workplace. Potential risks include swine flu, active TB, SARS, seasonal flu, and COVID-19. We will generally follow the guidelines set forth by the Centers for Disease Control and Prevention (“CDC”); however, the universal precautions generally include staying at home when ill, frequent hand washing, ready access to hand sanitizer, wearing a mask to prevent airborne spread, latex gloves, annual flu vaccinations, and encouraging supervised persons to take regular exercise and maintain a healthy and well-balanced diet. Key trigger issues that would activate these pandemic steps include escalating staff losses due to illness, an inability to manage business operations adequately, and/or orders from Federal, State, or local governmental entities. Based on the facts and circumstances surrounding a pandemic outbreak, the Company will decide when to invoke the BCP and to what extent. To this end, we will evaluate the situation to determine the impact on Stride Wealth’s operations, determine the level of backup that will be needed, notify appropriate emergency organizations (e.g., hospitals, clinics, etc.) if appropriate, and assign responsibilities and activities to other supervised persons to ensure the Company’s ability to maintain business operations. If the pandemic escalates to the point where a supervised
person’s immediate family may be affected, the Company will notify the family members quickly. If necessary, we will move unaffected employees to our alternative office location and/or have supervised persons work from home to restore normal business operations.
10.6. Denial of Service
When a Denial-of-Service (“DoS”) attack is suspected, the priority is to identify and confirm the attack by monitoring network traffic for unusual spikes or patterns. The Incident Management Team will direct the use of tools such as intrusion detection systems or firewall logs to help verify the presence and nature of the attack. Once confirmed, Stride Wealth will immediately take steps to contain and mitigate the impact. This includes activating DoS protection features on firewalls or routers, blocking suspicious IP addresses or regions, and, if possible, redirecting traffic through a content delivery network (“CDN”) or a third-party scrubbing service that can filter malicious traffic. Simultaneously, the Incident Management Team will notify key stakeholders, including cybersecurity teams, management, and, where applicable, our hosting provider or internet service provider, to determine whether external partners can provide additional support to filter or block malicious traffic upstream. The Incident Management Team will preserve all generated documentation, including logged network activity, error logs, and relevant data, to aid in a later investigation or potential legal action. After the attack subsides, the next step is to recover and restore services. This may involve restarting affected systems, patching vulnerabilities, and verifying that no permanent damage or compromise has occurred.
10.7. Succession Planning
Stride Wealth will cross-train personnel to ensure at least one additional team member is familiar with each client’s account. This includes conducting periodic exercises that simulate the temporary unavailability of key personnel, allowing backup staff to manage client accounts and maintain continuity of service. In addition, the owners of Stride Wealth will take proactive measures to establish and maintain a comprehensive estate plan. This may include preparing wills, trusts, or other legal instruments to clearly outline succession and ownership transfers in the event of an owner’s death. Firm personnel will be informed of these plans to ensure a smooth operational transition. The owners will also develop a detailed checklist, maintained by their legal and financial representatives, which offers clear guidance for executors, trustees, heirs, and remaining employees. This checklist outlines procedures to follow in the event of the death or extended unavailability of any founder, owner, or other key individual, ensuring continuity and clarity in firm operations.
11. EMPLOYEE AND SUPERVISED PERSONS AWARENESS OF PLAN
The Company will take steps to both educate and increase the awareness of its employees and supervised persons with respect to Stride Wealth’s Plan, and the current actions being taken to address such issues by the financial services industry and the Company. The Company will provide all supervised persons with access to the Plan.
12. NOTIFICATION
In addition to any action taken by Stride Wealth with respect to disruption of its business processes which relate to the ability of the Company to deliver financial services to its clients, Stride Wealth will promptly notify the appropriate Regulators of any such problems.
13. MANAGER APPROVAL
In my capacity as the BCP Designated Principal for the Company, I have approved this Business Continuity Plan for the Company, effective as of the date set forth herein, as being reasonably designed to enable Stride Wealth to meet its obligations to clients in the event of an SBD.
Tanner Erickson, BCP Designated Principal
14. GLOSSARY
Application
A computer program or set of programs designed to help people perform certain types of work.
Assessment
The process of identifying core business areas and processes, completing an inventory, and analyzing systems supporting the core business areas, prioritizing their conversion or replacement, identifying risks and the necessary resources.
Business Function
A group of logically related tasks that, when performed, accomplish an objective.
Business Continuity Plan
A contingency plan that describes the steps a company would take, including the activation of manual or contract processes, to ensure the continuity of its core business processes in the event of a business interruption-induced system or process failure.
Company
Stride Wealth LLC
Defect
A problem or "bug" that, if not removed, could cause a program to either produce erroneous results or otherwise fail.
Mission-Critical System
The loss of these critical functions would cause an immediate stoppage or significant impairment to core business areas.
Outsourcing
Paying another company or individual to provide services that an organization might have otherwise performed itself (i.e., software development, payroll).
Regulators
Refers collectively to the SEC, FINRA, and other regulatory entities with jurisdiction over the Company's business activities.
SBD
Significant Business Disruption.
SEC
United States Securities and Exchange Commission.
Office Location(s)
Main Office Our main office is located at 21296 East Superstition Dr., Queen Creek, AZ 85142. Its telephone number is 480-349-7085. Our employees may travel to that office by car or public transportation. Its mission-critical systems include desktop computers and phone systems.
Corporate Telephone Directory
Tanner EricksonCell Phone: 480-349-7085Office email: tanner@stridewealthgroup.com
Regulator Contact Information The following sets forth a list of the primary Regulators that the Company submits filings and/or reports to on a regular basis, including addresses and phone numbers: Arizona Corporations Commission Securities Division 1300 W. Washington Street, 3rd Floor Phoenix, AZ 85007 602-542-4242 securitiesdiv@azcc.gov
IARD Web Site:https://gateway.finra.org
Critical Business Constituents
Primary SuppliersThe LeGaye Law Firm2002 Timberloch Drive, Suite 200The Woodlands, TX 77380Phone: (281) 367-2454www.legayelaw.comCharles Schwab & Co., Inc.211 Main StreetSan Francisco, California 94105800-435-4000www.schwab.comDatatek LLC935 E. Main St. #202Mesa, AZ 85203480-800-0989www.datatekaz.comWells Fargo Bank3222 E. Ray RoadGilbert, AZ 85296480-840-6240www.wellsfargo.comCox Communications20401 N 29th Ave, Ste 100Phoenix, AZ 85027866-272-5777www.cox.comGoToConnect562-577-0499suzanne.condon@goto.com
Attachment E
Stride Wealth LLC, an independent financial advisory firm, has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Because the timing and impact of disasters and disruptions are unpredictable, we must be flexible in responding to events as they occur. With that in mind, we are providing you with this information on our business continuity plan. Contacting Us – If, after a significant business disruption, you cannot contact us as you usually do at 480-349-7085, you should go to our website at www.stridewealthgroup.com and contact us by email. Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. Our business continuity plan addresses: data backup and recovery; all mission-critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank, and counterparty impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business. Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, disruption severity can range from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within a feasible period of time. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and recover and resume business within a feasible period of time. In either situation, we plan to continue in business and notify you through our website www.stridewealthgroup.com or our customer emergency number, 480-349-7085, on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will ensure our customers’ prompt access to their funds and securities. For more information – If you have questions about our business continuity planning, you can contact us at 480-349-7085.
This plan is subject to modification; an updated summary will be promptly posted on our website, and customers may alternatively obtain updated summaries by requesting a written copy by mail.