21 Apr Is Your Business Continuity Plan COVID-19 Proof? SEC Sweep Examinations Are Upon Us
In response to the COVID-19 crisis, the Division of Investment Management has also encouraged firms to “evaluate their business continuity plans.”1 The SEC is conducting sweep exams focused on Business Continuity Plans (“BCP”) with precise attention to the continuation of operations during the COVID-19 pandemic. Furthermore, regular examinations may include more focus on the firm’s BCP at this time.
Evidence requested by the SEC during these examinations include:
- Business continuity plan and other firm compliance policies and procedures addressing the continuity of business operations.
- Firm-issued policies, procedures guidance and other information tailored to address the continuity of the business operations specific to pandemics.
- Unforeseen issues or weaknesses in the activation of the BCP plan during the COVID-19 pandemic.
- How the BCP plan addresses the resiliency practices of third-party vendors, service providers and partners.
- Cybersecurity and policies and procedures regarding employee remote access – for more information on this topic, please see the Alaric Alert: COVID-19: Protecting Employees Without Sacrificing Cyber Security.1111
- General questions regarding difficulty or limitations in the ability to operate critical systems and operations during the pandemic.
Firms need to prepare responses to inquiries and information requests from regulators concerning their BCP’s and their response to the COVID-19 pandemic. Be sure to assess your current BCP to focus on maintaining business continuity and security when most or all of the workforce is remote.
SDDco Group can assist firms in reviewing and updating their business continuity plans and their pandemic continuity plans to comply with regulators expectations. Leveraging our industry expertise, our team of former regulators, professionals and in-house chief compliance officers can help your firm be exam ready.