SEC's business continuity plan proposed rule

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July 2016

Overview

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.

  1. Investment advisers can leverage existing business continuity planning requirements.
  2. BCPs should identify reliance on key third-party service providers. 
  3. Investment advisers and funds should consider third-party backup plans. 
  4. BCPs will also need to account for key operational risks. 
  5. Proposed transition planning is not detailed and faces questions.

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Dan Ryan

Partner, PwC US

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