It is easy to indulge in navel-gazing when it comes to business continuity. We examine your business, its components, its requirements, its objectives and the risks that could affect it.
Then we draw up business continuity plans and put them into action. Yet a business only means something if it has customers it can serve.
It is remarkable therefore to see how FINRA (the US Financial Industry Regulatory Authority, Inc.) emphasises the notion of the end-customer when defining requirements for financial firms to create and maintain business continuity plans.
With its Rule 4370 (are there really 4369 rules before this one?!), it specifies that BCP procedures must be designed so that existing obligations to customers can be met.
Compared to some organisations, this stance is highly outward-looking, and rightly so, when customers entrust companies with their money.
FINRA’s emergency preparedness rule (Rule 4370) obliges a firm to “disclose to its customers how its BCP addresses the possibility of a significant business disruption and how the firm plans to respond to events of varying scope”.
Not only that, but the disclosure must be made to customers when they start doing business with the firm, be displayed on the firm’s website (assuming there is one), and mailed to customers on request.
Funnily enough, what FINRA insists that firms in its sector do also makes good business sense when done on a purely voluntary basis.
Even if your company works in cosmetics industry (to take an example at some distance from that of financial securities), “customers” of all sorts still depend on being able to buy, sell, resell and distribute your products.
In that sense, FINRA rules are less a set of constraints and more a blueprint for how to get ahead and win more business because customers feel more secure in dealing with you.
As a bonus, FINRA has also contributed to the Small Firm Emergency Partner Program (SFEPP), designed to help groups of smaller businesses help each other in business continuity – yet another idea of potential interest to enterprises in the non-financial arena.