Seward & Kissel briefing

Seward & Kissel’s memorandum examines the Securities and Exchange Commission’s (SEC) proposed written business continuity and transition plan requirement for registered investment advisers.

18 July 2016

Publication

On 15 July 2016, Seward & Kissel published a memorandum which examines a proposed new rule (the Proposed Rule), issued by the Securities and Exchange Commission (SEC), that would require registered investment advisers to adopt and implement written business continuity and transition plans.

Under the Proposed Rule, an adviser's business continuity and transition plan must be reasonably designed to address operational and other risks related to a significant disruption in the adviser's operations. Each adviser would also be required to conduct an annual review of the adequacy and effectiveness of the implementation of its plan, and to maintain related specified records.

The SEC will receive comments on the proposed rule until 06 September 2016.

For more information contact an attorney at Seward & KisselRichard Perry or Devarshi Saksena.

This document (and any information accessed through links in this document) is provided for information purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking or refraining from any action as a result of the contents of this document.