On June 28th, the SEC proposed a rule that would require investment advisers to adopt and implement formal business continuity plans (BCPs) outlining how they would minimize investor impact in the event of a major disruption to their business.The proposal is a continuation of the SEC’s efforts to modernize and enhance oversight of asset managers.
- Investment advisers can leverage existing business continuity planning requirements.
- BCPs should identify reliance on key third-party service providers.
- Investment advisers and funds should consider third-party backup plans.
- BCPs will also need to account for key operational risks.
- Proposed transition planning is not detailed and faces questions.