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122. Employees personal use of social media for business purposes
Our policy is to have employees not use personal social media for business purposes. If we
discover they are, our policy is to have them remove the offending material and review our P&P. There may also
be a suspension or termination, depending on the infraction.

123. Not providing appropriate training for firm personnel
Our policy is to train all employees in their respective roles. If it is discovered that someone
needs training, our policy is to provide it.

Branch/Remote Offices
124. Remote office locations not being supervised
Our policy is to supervise all locations. If it is discovered that a location is not being supervised, it
is our policy that the supervisor be required to review the P&P and COE, possibly suspended or terminated.

125. Remote offices not integrated onto firm systems
Our policy is to not have all of our systems integrated for cybersecurity reasons. Our emails,
Schwab Advisor Platform, Redtail, Black Diamond and Cornerstone are online integrations. But our computers are
not tethered together for security purposes.

126. Not disclosing where all books and records are maintained
Our policy is to have all books and records maintained in a single location. If we discover that we
haven’t disclosed where they are maintained, then our policy is to update the appropriate documents.

127. Remote offices not being disclosed on the ADV and not properly registered as applicable
Our policy is to disclose all remote locations and have them properly registered. If we discover
that remote locations are not disclosed properly on our Adv or properly registered, we will be calling RIA in a BOX
for answers.

Books and Records
128. Firm not maintaining all required books and records
Our policy is to maintain all required books and records. If we discover that they are not up to
date, our policy is to bring them up to date as soon as possible.

129. Records maintained electronically not being backed up
Our policy is to electronically back up all records. Schwab deals with most of this since we send
everything to them electronically. If we discover anything we need to backup hasn’t been, our policy it to back it
up on a secure location.

130. Unauthorized access to firms books and records
Our policy is to limit access to our books and records. If it is discovered that there has been a
breach, then our policy is to determine the extent of the breach and notify any affected clients and offer 1 year of
credit monitoring

131. Not being able to produce records in a timely manner for regulator inquiries
Our policy is to maintain all required books and records. If we discover we are unable to produce
them, our policy is to look into back up files for the needed documents.

132. Records not being maintained for a minimum of 5 years from the end of the calendar year in
which the record was created
Our policy is to maintain all required books and records. If we discover we do not have 5 years
available, we would go to the back ups for copies.