10 Things to Document When Implementing Your Business Continuity Plan
In the COVID-19 pandemic, widespread shutdowns and stay-at-home orders are in place. Under these circumstances, maintaining thorough documentation of your firm’s Business Continuity Plan implementation is critical. Regulators have already started querying firms on their pandemic response and reviewing BCP measures. As such, firms should prepare to be examined on their BCP implementation; below are ten items you should document about your business’ response to the current crisis:
1. The date your firm implemented its Business Continuity Plan in response to the pandemic
2. Identification of Response Team members
3. Work locations of employees (remote or in the office)
4. A summary of critical or essential business functions, such as mail collection and IT support for employees working remotely
5. A summary of critical dates, like shifts in business operations, the day your physical office closed, or when staff was significantly reduced to fulfill minimum business operations
6. Any exceptions to your firm’s documented policies and procedures or any changes to policies as a result of the crisis
7. A summary of any quarterly or semiannual tasks which were delayed or changed and when you intend to complete them
8. Response Team activity, including a summary and dates of meetings and copies of crisis communications to employees, clients, or service providers
9. A summary and dates of any incident response training provided to employees
10. Details of additional vendor due diligence conducted due to the pandemic, including which vendors were contacted and any issues noted or resolutions made (e.g. engaging an additional service provider to fill operational gaps created by the pandemic)
Thoroughly documenting your firm’s BCP implementation now will save time and effort later and help prepare for future regulatory exams and incidents. If your firm needs additional support with implementing, updating, or documenting its policies and procedures, Fairview can help. Reach out to us you have questions about response planning and implementation or for guidance with other business continuity concerns.
