The rule has nothing directly to do with supply chains. I link it here mostly as another example of the increasing attention that is being given to risk and resilience. The proposed rule specifically notes:
It is critical for investment advisers to focus on resiliency so that they can continue to provide services to their clients when events impact the availability of systems, facilities, and staff. The ability to recover such systems, including third-party vendor provided platforms and services, and business operations in a timeframe that meets business requirements is important to mitigating the consequences of disruptive events.The proposed rule gives particular attention to each of the following five elements:
- maintenance of critical operations and systems, and the protection, backup, and recovery of data;
- pre-arranged alternate physical location(s) of facilities and/or employees;
- communications with clients, employees, service providers, and regulators;
- identification and assessment of third-party services critical to the operation;
- plan of transition that accounts for the possible winding down of the business or the transition of the business to others in the event the adviser is unable to continue providing services.
While considerably different in context, attention to each of these elements aimed at financial advisers would also enhance the resilience of supply chains.
Consistent with the SEC culture of investor transparency, the rule also proposes to make the business continuity plan substantially available to the public.
The proposed SEC rule can be found here.
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