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Planning for Compliance’s “Next Normal”
Author: Paul A. LiebermanDate: May 5, 2020
Most enterprises and institutions were caught flat-footed by the COVID-19 pandemic despite their Business Continuity or Disaster Recovery Plans (“BCPs” and “DRPs”). Now is the time for “after-action risk assessments” (“AARAs”), prior to re-opening, so that your firm’s step up to the “Next Normal” is not a step off the edge!
There are a variety of strategies and methodologies to implement your AARA, but all of them require prompt action right now. Firm management needs to seize the initiative and become the ‘tip of the spear’ for entering the Next Normal. Immediate action is especially critical for firms in the Financial Services industry—Broker-Dealers, Registered Investment Advisers, Funds and Insurance Companies should expect that their BCPs or DRPs and their Written Supervisory Procedures (“WSPs”) will be evaluated by the SEC, FINRA, or state agencies.