Business Continuity Plan
General BCP for Castle Wealth Advisors LLC
Approved by Executive Management
04-2016
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Table of Contents
Document Overview/ Revision Control
Introduction
A. Overview
B. General Guidelines
C. Policy Statement
Business Continuity Planning Process
A. Business Impact Analysis
B. Risk Assessment
C. Risk Management
D. Risk Monitoring and Testing
Roles and Responsibilities
A. Executive Management
B. Business Continuity Management Team
C. Branch Office/ Department Management
Activation of the Plan
A. Declaring a Disaster/ Disruption
B. Defining a Disaster/ Disruption
Pandemic
Incapacity or Death of Chief Executive Officer
Data Backup and Recovery
Incident Response and Business Resumption Tasks
A. Objectives
B. Defining An Incident
C. The Command Center
D. Incident Notification
E. Communications with Regulators
F. Public and Media Relations
G. Internal Communications
H. Damage Assessment
I. Contingency Site Preparation and Business Resumption
J. Safety and Security
K. Human Resources Tasks
L. Legal/Insurance
Appendix: Corporate Contact List
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Document Overview:
Date Created
Version
Document Classification
Owner
Status of Document
Last Approved
02-25-2016
2.0
Confidential
Misty Heather Castle
Final
04-15-2016
This is a controlled document and should be treated as such. All reservation and
updates shall be documented in the below revision control table and documented to
be best ability of the author. A new version of this document shall not be created
without revision control being updated.
Revision Control:
Date Modified
02-20-2016
02-24-2016
02-25-2016
04-15-2016
Revision Author
Heather Castle
Heather Castle
Heather Castle
Heather Castle
Author Phone
205-310-1888
205-310-1888
205-310-1888
205-310-1888
Define Update
Plan Creation
Final version created
Final version approved
Revision approved
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Introduction
A. Overview
As part of its fiduciary obligation to its Clients, and as a matter of best business
practices, Castle Wealth Advisors LLC (CWA or the Firm) has commissioned, and
management has approved, this General Business Continuity Plan (BCP) pertaining
to all office locations, should there ever become more than one. The plan serves as a
centralized repository for the locations Business Continuity (BC) information,
procedures, details the roles, responsibilities and tasks needed to effectively and
efficiently respond to BC event and to resume mission-critical, time-sensitive
business operations and services. This plan is designed to dictate an overview of the
policies and procedures of a recovery effort as well as identify key business
departments and personnel. This information will assist the company in resuming
operations, and to services its clients in a timely manner. Castle Wealth Advisors,
LLC had developed and implemented this BCB to continue an acceptable level of
business performance in the near term and resume normal business operations as
soon as possible.
B. General Guidelines
The Plan sets forth the following general guidelines:

The Business Contingency Management (BCM) Team, will prepare and
submit the Plan to Executive Management for review and approval.

The Owner is responsible for oversight of the Business Continuity planning
process, including the maintenance, testing and revision of this plan. The
Owners will review and approve the plan at least annually or when the
environment or business focus changes significantly (eg., a material change
to the Firm’s location, physical infrastructure, or scope of business or
operations.

The BCM Team, currently Owner, will maintain the plan on an ongoing basis
and test the plan, completely or in part, at least annually or more frequently
as determined by Executive Management. The BCM Team will determine the
scope, objectives, and schedule of each test.

The objectives of east test are to verify the compatibility and performance of
CWA’s back-up resources and identify strategic/ procedural enhancements
to the BCP in meetings the needs of the organization.

All testing should facilitate training of employees with respect to their
responsibilities.
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.

The BCM Team will document the results of each test, make any necessary
changes to the plan, and submit the test results and the updated plan to
Executive Management for review.
C. Policy Statement
It is the Policy of Castle Wealth Advisors LLC, that a viable Business Continuity Plan
be developed and maintained in order to provide prompt recovery from business
impacting disruptions ranging from a temporary loss of power, to a major
catastrophe, such as the total destruction of a building or a major damage to a
region of the country. The life safety of our employees and visitors while protecting
the assets of the company and our clients is the top priority of the plan, as well as
assuring our clients access to their funds and securities in the event of a business
impacting disruption.
The plan should conform to regulatory requirements and good business practices
and be consistent with the provision and direction of Castle Wealth Advisors LLC
strategic and tactical business plans.
Business Continuity Planning Process
A. Business Impact Analysis
The Operational Risk Committee/ Executive Management shall review and approve
at least annually the Business Impact Analysis (BIA) and its identified Business
process developed by the BCM Team. The Executive Management Team will be
presented with an executive summary of any significant findings once this annual
process is completed.
Objectives of the BIA include the following:

Assess and prioritize Castle Wealth Advisors LLC, business functions that
must be recovered, including interdependencies among critical operations,
personnel and services

Identify the potential impact of business disruptions resulting from
uncontrolled, nonspecific events

Identify the potential impact of legal, regulatory, financial, reputational, and
other such impacts on identified process.

Establish Recovery Time Objectives (RTO) and Recovery Point Objections
(RPO) to establish the Maximum Allowable Downtime (MAD), as well as the
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
acceptable level of loss (eg., data, operations, financial, reputation,
regulatory, etc.), associated with each identified process.

Each identified function will be prioritized based on its RTO and RPO aiding
in the critical path recovery of systems and functions by imbedding both RTO
and RPO numbers to each application supporting the function.
Current BIA reports are housed on a shared drive allowing for restricted access and
availability in the event they are needed during an incident.
B. Risk Assessment
The Executive Management shall review and approve at least annually the Business
Continuity Risk Assessment. This risk assessment shall be incorporated into the
overall Information Security Program risk assessment.
The purpose of the risk assessment is to evaluate business functions and the BIA
assumptions under various threat scenarios. Threats to be considered as part of the
assessment include, but may not be limited to:




Environmental disasters (Eg., earthquakes, tornados, hurricanes, flooding,
fires, snow or ice storms)
Pandemic events (eg., flu outbreak)
Theft of data loss from negligent or malicious individuals (eg., terrorists,
hackers, rogue employees)
Infrastructure failure (eg,. Power outages, equipment failures)
Management shall analyze the impact, likelihood, and resulting severity of identified
threats in order to prioritize its business functions and estimate how they could be
disrupted under the various threat scenarios.
C. Risk Management
Based on the results of the BIA and Risk Assessment, management shall develop
appropriate strategies and procedures to recover, resume, and maintain its critical
business functions in the event of a business-impacting event.
D. Risk Monitoring and Testing
Testing the BCP is an essential element of preparedness. Management conducts
tests of its BCPs at least annually to ensure the plans remain current and are
effective. The tests ensure that all member of the recovery team and any relevant
staff are aware of the plan(s) their roles and responsibilities as defined by the
plan(s).
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
The testing program shall incorporate the following elements:




Defined roles and responsibilities of key personnel. IT Management, Crisis
Management, Corporate Facilities, Internal Audit (or other independent
party), ect.
Testing policies and related strategies.
Procedures for execution, evaluation, independent assessment, and reporting
of test results.
Updates to the BCP and testing program
Testing methods may include, but are not limited to, tabletop exercises, walkthrough reviews, workspace relocation, ENS notification exercises, functional drills,
and interruption tests. After reviewing the test results, a list of recommended
improvements and lessons learned shall be developed for review by management
and for use in future exercises. All applicable improvements are implemented into
the BCP test plan.
Castle Wealth Advisors LLC, Business Continuity planning as an iterative process
that must be continually updated and improved.
Roles and Responsibilities
A. Executive Management
Executive Management will provide guidance in the management of an incident
resulting in the loss of access to primary work place for Castle Wealth Advisors LLC
business location and/ or loss of key dependencies at the business location from 24
hours to 30 days.
B. Business Continuity Management Team
This leadership implementation team will manage, administer and implement the
contingency plan. This team shall be reviewed annually by the Executive
Management, at which them any member is deemed unable to complete his/her role
as outlined below. Once approved by the Executive Management the team may
appoint additional members as needed.
The team is authorized to take action as necessary to regain full utilization of Castle
Wealth Management resources, or alternative sites, as necessary, within the
guidelines set forth within this Plan. Actions taken and decisions made jointly by no
less than two of the approved team members is considered action by and for the
entire team. The CEO of the company may act alone if no other members of the
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Executive Management are available to confer with at the time of the event and it is
in the best interest of the company that a decision be made in a timely manner.
Ensuring that the plan reflects ongoing change is crucial. The Business Continuity
Management team coordinates and is responsible for the maintenance, periodic
testing and revision of the plan and for ensuring that any company personnel have
access to the plan and are trained I its basic components. General oversight and
review of the plan will be under the Operational Risk Committee (ORC).
Name
Lead: Heather Castle
Alternative: TBD
Title
CEO
C. Branch Office Management
Branch Office Management will be responsible for the safety of personnel, relocation
efforts to designated contingency sites, and damage assessments regarding the
affected site. Team members as defined in this plan will be responsible for the roles
and responsibilities that have been assigned to them.
Detailed descriptions of the roles and responsibilities described are presented in the
Incident Response and Business Resumption Tasks section of the Plan.
Activation of the Plan
A. Declaring a Disaster/ Disruption
Executive Management, in coordination with the BCM Team, will determine whether
and when to activate this Plan. If affirmed, the Business Continuity Management
Team will initiate emergency notifications to Castle Wealth Advisors, LLC, personnel
(should any exist) and activate the entire Plan or phases of the Plan, as required.
B. Defining a Disaster/ Disruption
Low Impact





Temporary inability to process work, with the likelihood that processing will
functions adequately within 2 hours
Trading and clients access to funds and securities are available immediately
via duplicate circuits and technical environments
Minimal impact on the safety and soundness of the organization
Minimal impact on the reputation of the organization
This dose not constitute a Disaster
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Intermediate Impact





Temporary inability to process work at the home office of Castle Wealth
Advisors LLC/ company wide, with an expected resolution timeframe
(generally one day)
Personal and workload may be transferred to alternate locations
Trading and client access to funds and securities are available immediately
via duplicate circuits and technical environments
Possible financial impact on the organization
Possible impact on the reputation of the organization
High Impact









Inability to process work and/ or service customer needs for an
undetermined length of time, generally, more than two days.
Personal and workload will be transferred to alternate location due to unable
or hazardous conditions.
Life safety of personal could or is impacted by the present environment
Likely adverse impact on the safety and soundness of the organization
Trading and client access to fund and securities are available immediately via
duplicate circuits and technical environments
Likely adverse impact on the reputation and market risk of the organization
Trading and client access to fund and securities are available immediately via
duplicate circuits and technical environments
Likely adverse impact on the reputation and market risk of the organization
Generally includes catastrophic natural disasters (eg., earthquake, tornado,
hurricane); and other large-scale events (eg., pandemic flu or terrorism);
may also include computer or information system security breach where
highly sensitive data is compromised.
Pandemic
In the event that a pandemic is projected to impact the Firm, management shall
review the projections made by relevant authorities, including local or state police,
government officials, community public health officials, the World Health
Organization (WHO), or specialists in the medical field. Specific actions will be
taken based on direction received from these authorities. Leading up to, during and
post Pandemic Management will refer to the approved Castle Wealth Advisors LLC,
Pandemic Plan for guidance and the Human Resources (HR) department.
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Incapacity or Death of Chief Executive Officer
The company has developed a separate succession plan in the event of the death or
incapacity. In the event the Chief Executive Officer is incapacitated or deceased,
Executive Management, consistent with the succession planning exercise of the
other Executive Management Members (should any exist), will appoint an interim
officer. These members would act as the interim company leaders in the event the
current CEO is unable to perform their duties.
Data Backup and Recovery
Castle Wealth Advisors, LLC. maintains its primary books and records as described
below:

Firm Records: Electronically on computer hard-drive, with the ability to edit
documents locked. A back-up copy will be located on external hard drive and
be updated weekly. Additionally, files will be updated on a monthly basis
and held on jump drive offsite in a secure location.

Customer Records: Electronically on cloud server and two additional
electronic records on an external hard drive updated weekly and a jump
drive updated monthly and held offsite in a secure location. All hardcopy
records will be held for 6 months at primary location and then boxed and set
to storage off-site in a secure location.
Castle Wealth Advisors LLC conducts incremental backups every evening with a full
backup taken no less than once per week. The e-mail server is subject to a full
backup nightly.
Shadow backups are also employed allowing recovery of files without having any
impact on production systems. These backups are taken multiple times through out
the day for overall file restoration convenience.
In the event of a disaster that causes the loss of our electronic records, we will
recover them from our other electronic records where possible. For the loss of
electronic records, we will either attempt to physically recover the storage media or
electronically recover data from our backup site; or, if our primary site is
inoperable, continue operations from out backup site or and alternate location.
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Incident Response and Business Resumption Tasks
A. Objectives
The overall objectives of Incident Response and Business Resumption in the event
of a significant disruption or disaster are to:


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


Life safety, ensuring safety and health of any employees (should there ever
be employees)
Limit and contain damage to the facilities and equipment
Stabilize operations/ services
Manage and communicate information about the incident to customers,
regulatory parties, suppliers and vendors
Coordinate and manage overall response and recovery efforts
Prepare and begin operations at the assigned contingency site(s)
B. Defining an Incident
Low Severity



Minor annoyance or threat
Disrupts a very small number of network devices or systems
Has little or not risk of propagation or causes minimal disruption of damage
in its attempt to propagate
Example:
Isolated infection; malware on non-critical systems
Intermediate Severity


Having a moderate probability of propagating to other systems
Adversely impacts a moderate number of systems and/ or people, such as an
individual department, unit, lightly populated building or branch site
Example:
Attempts to gain unauthorized access
High Severity
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.




A current or future incident that has been identified as a serious threat to the
organization
A threat that requires immediate attention or action
Any action that threatens the confidentiality, integrity, or availability of
critical business and information systems or confidential information (ie.,
employee, customer, and intellectual property, or third-party vendor date)
Life safety of employees is at immediate risk
Example:
Malicious code, unauthorized access, affecting critical services or a compromised
host containing sensitive data. The home office location is highly impacted by a
natural or manmade event and is rendered inaccessible.
C. The Command Center
The Command Center is the physical location at which coordination of information
and resources to support management incident activities takes place. The
Command Center may be located on-site or in a temporary or permanent facility or
be Virtual via a conference bridge. The Command Center should be located away
from the emergency scene. Castle Wealth Advisors LLC has chosen the Beverly
Hilton Hotel (Address: 9876 Wilshire Blvd, Beverly Hills, CA 90210
Phone:(310) 274-7777) as Command Center should something happen which
prevents/ limits access to primary location.
The purpose of the Command Center:





Command and control coordination and communication
Organizing responses and evaluation of incident
Tracking and monitoring of business continuity needs to determine which
business continuity plan needs to be implemented
Tracking responses- track personnel and other deployed resources
Updating employee, public, external agencies and executives
The CMT will determine what other Company personnel are need and appoint
specific personnel to assume these roles depending on the incident, in the event
employees are ever hired.
Additionally, in the event of power outage or business interruption:
1. Business phone number (424-209-2257) will be remotely call forwarded to
alternative phone. This will ensure that should a client, employee, regulator
or business partner can contact Castle Wealth Advisors LLC.
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
2. Business mail and communication can be held and picked up from local post
office or FedEx facility.
D. Incident Notification
Corporate Services will provide building management or designee with telephone
numbers of key Castle Wealth Advisors, LLC. contacts. Upon notification, from
either building management or Castle Wealth Advisors, LLC management, the BCM
Team will meet either in physical designated locations, identified virtual locations or
in the event of a building evacuation, at designated assembly points. Initial incident
assessments will be preformed and recorded and a situational update reported to
Executive Management. If necessary the Crisis Management Team (CMT) will
convene and advise local resources of further actions.
Responsibility
Task
Building Security
When an incident occurs, the on-site security (The BW Apartments management
team) will contact Corporate Services (Heather Castle) with the following:
1. Name
2. Location
3. Description of Incident
Corporate Services
Emergency Notification. After being notified of a situation, Corporate Services will
assess, and if appropriate notify the BCM Team, Crisis Management Team and the
Damage Assessment Team.
Will assemble the following:
1. Corporate Services will attend to affected site location until the Emergency
authorities arrive
2. Provide support for any team members
3. Evacuate personnel, if necessary
4. Secure site
5. First Responders should be contacted as necessary
Damage Assessment
After being notified of a situation the Damage Assessment Team will designate a
representative to be the liaison (Heather Castle) with first responders. If allowed to
return to the building they should do a general assessment of the overall condition
of the site.
The Damage Assessment Team will report information to Corporate Service or CMT.
Items to Report:
1. Physical structure of the building
2. Security systems: include access control, fire prevention
3. Are access routes available
4. Environmental support systems such as air condition, heating, plumbing,
electrical wiring, power supply
5. Hard copy files
6. Telecommunications equipment
7. Computer Systems
8. Affected personnel and their safety status
Life Safety is a primary goal and no person should enter a facility if they have not been cleared by onsite
first responders or other like personal. Whenever possible take photographs to record visual damage to
site and equipment.
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
In the event of a shutdown, as pertinent, the Company will utilize their Emergency
Notification System (ENS) to email and call any employees potentially impacted by
the event.
E. Communication with Regulators
In the event of a shutdown, the Company will use most effective available means to
communicate with its regulator and to meet any regulatory requirements
precipitated by the particular circumstances.
The Chief Executive has the primary responsibility for communication with
regulators during and SBD.
F. Public and Media Relations
Executive Management is responsible for approving all major communications with
the public, including media releases and notifications to customers.
The Crisis Communications Team will manage the information flow and content
throughout the resumption phase. At Executive Management’s direction, this team
will assess the audience and determine the most appropriate and efficient delivery
mechanism available.
Heather Castle, CEO, will have final approval for outside media and
communications. All communication with the media is to be undertaken by the
direction of the CEO.
Responsibility
Task
Crisis Communications
Press release should be prepared in advance. They should be clear, factual,
and concise, with related information distributed from a single source. All
press releases must have prior approval from the CEO
The Crisis Communication Team should:
a. Be available to the Media at all times
b. As appropriate, schedule communications with the media
c. Coordinate all press releases
Notifications to Customers:
1. Coordinate posting of notification to CWA’s website and to
subsidiary websites, as appropriate
2. Coordinate posting of alternate address and pertinent
information on physical building sites, as needed
3. Coordinate media coverage, if appropriate, to direct customers to
alternate sites
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
G. Internal Communications
The Crisis Communications Team is also responsible for all communications to
Castle Wealth Advisors LLC, associates (should any exist). This team will assess the
audience need and determine the most appropriate and efficient delivery
mechanism available as well as he information to be provided.
Responsibility
Task
Crisis Communications
Communication to Business Units.
Provide the following:
1. Time incident occurred
2. Expected duration of outage
3. Protocols to follow
4. Key methods of updates/ communications
5. Number to call f normal channels are not working
6. How to track expenses related to recovery
7. Vendors that have been notified
8. Status of recovery site
9. Method of obtaining customer statements
10. HR services, counseling, benefits, payroll
Family Support Communications:
Work with HR to coordinate any contact with families related to support
services being provided.
H. Damage Assessment
The Damage Assessment Team will be responsible for conducting the intimal
damage survey and assessing the probable length of a business site outage. A
determination of the level of disaster is to be made. Once made other teams will
become involved to further address impact and resumption.
Responsibility
Task
Damage Assessment
After being notified of as situation the Damage Assessment Team will
designate (CEO, Heather Castle) to be the liaison with first responders. If
the team is allowed to return to the building they should do a general
assessment of the overall condition of the site.
a.
b.
c.
d.
Determine physical structure of building
Security systems, access control, fire alarm, fire prevention
Are access routes available
Environmental support systems (air conditioning, heating,
plumbing, electrical wiring, power supply)
e. Hard copy files
f. Telecommunications equipment
g. Computer systems
Affected personnel (if any exists)
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Determine Impact and coordinate any repairs needed including
replacement of any damaged equipment.
K. Human Resources Tasks
Responsibility
Task
HR/ Admin
Travel Arrangements:
1. Coordinate travel and transportation to alternative site
2. Rent appropriate lodging for recovery team members
Procurement of Goods and Services
1. Coordinate purchasing and/or rental of additional office space,
computers, equipment
Administration of Personnel Issues:
1. Should an associate have injuries, coordinate medical coverage
and services
Secretarial/ Clerical Support:
1. Bring in additional help as needed
Compensation:
a. Coordinate compensation
b. Document and secure management approval of any special pay or
expenses
c. Ensure payroll recovery is undertaken
L. Legal/ Insurance
Responsibility
Task
BCM Team
Notify insurance rep of incident and coordinate involvement in site
reviews and initial adjustment activities
Monitor the collection and accounting of disaster related expenses
Prepare/ present preliminary and final loss and reimbursement
summaries to Executive Management
Assist in the preparation, review and evaluation the disruption in terms of
liability, regulatory requirements and contractual obligations
Coordinate legal aspects of crisis related responses to media inquires
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.
Appendix: Corporate Contact List
1.
Ernest Sampson, CEO
[email protected]
Private Client Services Broker Dealer
502-451-0600
2.
Steve Higdon, Chief Development Officer
[email protected]
Private Client Services Broker Dealer
502-797-5207
3.
John Taylor-Jones, Chief Compliance Officer
[email protected]
Private Client Services Broker Dealer
502-451-0600
4.
Mary Wescott, Chief Operations Officer
[email protected]
Private Client Services Broker Dealer
402-451-0600
5.
Jeremy Molsberger, Managing Principal
[email protected]
Private Client Services Broker Dealer
401-451-0600 ext 212
6.
Matt Adams
[email protected]
Charles Schwab
800-253-1110
7.
Emily Uhle
[email protected]
RIA in a Box
8.
Client Service
[email protected]
Private Client Services
(800) 966-9347
9.
Client Services
Charles Schwab
866-855-9102
The contents of this document, including and all exhibits and attachments, are confidential in nature and are
intended solely for the use of Castle Wealth Advisors LLC. Any other use, reproduction or dissemination of this
document is strictly prohibited.