Fund managers have been forced to completely reconsider the concept of business continuity based on issues raised during the coronavirus pandemic, as many existing solutions proved to be inadequate or ill-conceived. Those shortcomings are opportunities, however, as the pressure testing of business continuity plans (BCPs) during the crisis has revealed ways to improve them to protect against the next crisis. It has also cast a spotlight on the interplay of third parties in the process, both in how a fund manager prepares its own BCP and in the importance of considering those parties’ BCPs. This second article in a two-part series enumerates specific BCP updates fund managers should make to account for technology, employee and backup office considerations introduced by the pandemic, as well as to account for various third-party risks to address going forward. The first article
offered an overview of regulatory standards from the SEC, FINRA and other agencies to reference when updating BCPs, as well as insights for effectively undertaking the process of implementing, testing and maintaining BCP and disaster recovery plans going forward. See “Are You Prepared for OCIE’s Sweep of Business Continuity Plans and Coronavirus Actions?
” (Jun. 2, 2020); and “Former OCIE Private Funds Examiner Explores Compliance Issues Introduced by the Coronavirus Pandemic and Mitigation Tips (Part Two of Two)
” (Apr. 21, 2020).