Coronavirus Reaches Pandemic Status: You Better Pull Out The Old Business Continuity Plan

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Fox Rothschild LLP

Let’s be honest, the only people usually concerned about business continuity plans (“BCP”) are compliance folks and the lawyers.  In fact, many probably have not looked at their BCP since Hurricane Sandy.  Well, you better dust it off (or dry it off, more accurately).

FINRA has already provided notice regarding traders working at home.  https://www.bloomberg.com/news/articles/2020-03-09/finra-concedes-virus-may-impact-wall-street-oversight-of-traders.  Further, nearly everyone, who works at the SEC headquarters in Washington, D.C., has been sent home because a staff member tested positive for the coronavirus.   However, don’t get to happy about the SEC dispersion, staff members are still working around the country and from home.

In any event, firms need to start preparing and considering implementing their business continuity plans before it is too late.  Focus on the key functions: personnel, IT, and supervision.   Do your best, and remember legal counsel is there to assist.

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