9.4.18. Business Continuity Plans and Emergency Contact Information
According to an NASAA model rule, investment advisers must establish, implement, and maintain written procedures related to a business continuity plan (BCP) and a succession plan. The BCP must identify procedures to keep the business running in the event of an emergency or significant business disruption. A succession plan is a plan that designates who will take over specific activities if certain key personnel die or become unavailable.
The BCP must be designated to enable the investment adviser to meet its existing obligations to clients. The elements that comprise a business continuity plan or a succession plan may be tailored to the size and needs of the firm. For example, a succession plan for a sole proprietorship will be different from one for a large corporation. Every BCP should include provisions that:
• Ensure the protection, back-up, and recovery of the adviser’s books and records
• Detail a method for communications with customers, employees, and regulators
• Explain where an office will be relocated in the event that such relocation is necessary
• Name persons who will take responsibility in the event of death or