SEC Policy Statement: Business Continuity Planning for Trading Markets

Policy Statement: Business Continuity Planning for Trading Markets:

"A critical 'lesson learned' from the events of September 11, 2001 is the need for more rigorous business continuity planning in the financial sector to address problems of wider geographic scope and longer duration than those previously addressed. These events made clear the possibility of a large-scale regional disaster, resulting in a broad consensus in the financial community that business continuity planning needs to adapt to plan for events of wider scope and, in general, become more robust and resilient.

Since the September 11 attacks, the U.S. securities markets and market participants have taken significant steps toward this goal by demonstrably improving the robustness of their business continuity plans.

The Commission and other financial regulators also have been devoting substantial resources to efforts designed to strengthen the resilience of the financial sector. For example, the Commission, together with the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency, recently published an Interagency Paper on Sound Practices to Strengthen the Resilience of the U.S. Financial System that identified "sound practices" relating to business continuity planning for certain key market participants.

COMMENT:
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While they have emphasized the need to more rigorously test the plans they still have given the organizations the flexibility they require for specific operational functions. As an example, they have not "yet" mandated the minimum distance that operational facilities need to be located from each other. At some point, organizations will realize their vulnerability by placing both facilities within the same geographic region. This was ever more apparent in the United States with the recent northeastern blackout and the Mid-Atlantic hurricane events.