On June 28, 2016, the Securities and Exchange Commission (“SEC”) issued a proposal requiring SEC registered investment advisers to implement a written business continuity and transition plan (“BCTP”).1 In the corresponding press release,2 the SEC stated that the purpose of the proposed regulation is to minimize client harm by ensuring that advisory firms have BCTPs that are designed to address operational and other applicable risks surrounding significant business disruptions.
This Risk Management Update outlines the current requirements for business continuity plans vs. the newly proposed regulations and provides guidance and action steps advisory firms should consider in preparation for the issuance of the final rule.
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