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April 23, 2019

FINRA Reminds Broker-Dealers of Business Continuity and Disaster Recovery

Sadly, we are reminded that animals can experience serious danger and cause outages when they come in contact with power lines. Often, the culprit is a squirrel and such was the case in Montana recently, affecting 7,600 customers. Rarely, a racoon is the issue and this was the case this past weekend in Kentucky, leaving 2,000 homes and businesses without power.

Sometimes, there is an outage but we aren’t told why – like the one which took place in Union County, New Jersey recently, affecting more than 9,000 customers.

In addition, The Financial Industry Regulatory Authority or FINRA is reminding broker-dealers of their obligations to have business continuity and disaster recovery plans in place in a just-released Regulatory Notice.

Reg Notice 19-15 consolidates FINRA’s designation criteria for BDs that must have such plans, as previously announced in Notices 15-43 and 18-09, without change.

As required by SEC Regulation Systems Compliance and Integrity, or Regulation SCI, FINRA in 2015 adopted Rule 4380 requiring BD participation in business continuity and disaster recovery testing.

Reg SCI authorizes FINRA to designate firms that must participate in FINRA’s annual BC/DR test based on established standards, which FINRA first published in Regulatory Notice 15-43 and updated in Regulatory Notice 18-09.

Not all companies are regulated by FINRA but this organization is on the forefront of cybersecurity and business continuity. Such messages are a great wake-up call for all businesses that a solid plan needs to be in place to ensure your business stays up and running in the event of a disaster.

Such events could be weather, animal or cyberattack related.

Thankfully, quite often, the solution to each of these challenges is similar or, in some cases, the same.

The low-hanging fruit here is to ensure servers are backed up and have a UPS plus a generator. In addition, all important user files need to be backed up and ideally, a second location should be available if the first one isn't accesible or functioning.

Quite often, the cloud can be a great way to ensure a business stays running but even then, an SD-WAN or SD-Internet solution is a must to ensure an organization isn’t overly-reliant on a single provider.

The time to think about these issues is before there is a problem – or basically, immediately. Good luck to you and hopefully you will be able to weather your next “storm” without a hitch.

Often the best way to approach these issues is to work with IT services experts who can assist with Strategic IT Plans, Business Continuity and Disaster Recovery solutions.


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