Winter Weather Affect You? – FINRA 4370

If your firm, staff or Advisors have been affected by any of the storms this year, this may be an opportune time to document the events your firm is experiencing and satisfy 4370(b). There has rarely been a better time to test and document your Business Continuity Plan (BCP) procedures than a true disruption to your day-to-day operations.
Some of the items to review and document might be:

• Who is “in charge”? 4370(d)
• Do clients and staff know how to access your BCP?
• Was the calling tree implemented? Did it work?
• Were systems operational? Did employees and clients know how to access these systems?
• Was an alternative location used? Did staff worked from home?
• Was the staff able to login to critical systems? Did advisors have access?
• Were clients able to access their accounts? What about the firm or the custodian?

These are just some of the items that you should address during your test. It is unfortunate that some regions have been hit very hard by the winter storms but it does present an opportunity to test your procedures. This is also an area where the regulators will focus during a routine exam.

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