The Securities and Exchange Commission had indicated that it was going to tackle operational issues at investment advisers. It just released a proposed rule on business continuity and transition plans for registered investment advisers. The proposed rule would require SEC-registered investment advisers to have written business continuity and transition plans reasonably designed to address operational and other … Read more »
Tag: Disaster Recovery
Model Business Continuity Rule for Investment Advisers
There is no explicit requirement that an adviser or fund manager have a disaster recovery plan. But any manager trying to fund-raise knows that investors will ask about its business continuity plan. The SEC sort of requires SEC registered investment advisers to have a business continuity plan. It’s an easy one to miss in Rule … Read more »
How Good Is Your Business Continuity Plan?
The Securities and Exchange Commission wants it to be better. In the aftermath of Hurricane Sandy, the Securities and Exchange Commission joined the Commodity Futures Trading Commission and the Financial Industry Regulatory Authority in issuing a joint staff advisory on business continuity and disaster recovery planning. The advisory follows a review by the regulators after … Read more »
Sandy and Disaster Preparedness
Disaster recovery is an important, though not explicitly mandatory, component of compliance program. The Securities and Exchange Commission alludes to this in the release for the compliance rule. It’s also a key part of personal plan. I’m learning that first hand. My family is spending its third day without power. Fun and exciting at first, … Read more »
Technical Problems
Sometimes things just go wrong. No matter how hard you try (or don’t) you need to expect the unexpected. Software and systems inevitable break and go down. And when a system goes down, it will inevitably go down at the least convenient time. The key is testing, redundancy, and back-up. You can’t prepare for all … Read more »
Earthquakes, Hurricanes, and Disaster Recovery
Monday’s East Coast earthquake was far from a disaster. I just thought I had too much coffee, until I heard others in the hallway say “Do you feel that?” Then I realized the shaking was not just because I was over-caffeinated. Even though significant earthquakes are rare on the East Coast, hurricanes are not. Irene, … Read more »
Investment Advisers and Business Continuity Plans
When an investment adviser is designing its policies and procedures you need to identify the risks for their firm so they address those risks. A big risk is missing an applicable requirement under the regulatory scheme. So you sit down with the regulations and tie them to your specific policies and procedures. An easy one … Read more »
Swine Flu, Disaster Recovery, and Compliance
One aspect of a compliance program is disaster recovery. Investors want to know that your operations can be up and running if something goes wrong. Although first thoughts go to an extraordinary event like the World Trade Center attacks, the problem is more likely to be something less dramatic. From today’s headlines, it may be … Read more »