23 March 2020
Main Contributor: Elizabeth Cope, CPA, CSCP, CIPM, CEO & Lead Consultant
It didn’t take long for advisors to start receiving requests from underlying managers, investors and even the SEC on how they were responding to the pandemic. Areas being addressed, include, but are not limited to:
- A copy of your firm’s Business Continuity Plan (“BCP”) and any additional policies to how your firm responded to the pandemic,
- Whether or not employees have the capability to work remotely,
- Aspects of the BCP that have been implemented as a result of COVID-19,
- Whether your firm has identified any weaknesses or unforeseen issues and how you addressed them,
- Whether your firm has been impacted by third-party vendors and service providers, and
- If this has created a hardship for the firm (financial, human resources) and how the firm has addressed it.
Hopefully your firm had a BCP in place and started putting steps into motion when the pandemic hit. If you didn’t have a plan then now is as good a time as any to create a plan and start putting those steps in place so your firm can continue servicing your clients.
Testing and Micro-Adjustments
Now that your conducting a “live” test of your BCP, use this opportunity to document the results.
- What is working?
- What is not working?
- What adjustment have you had to make as a result of implementation?
You are not expected to be perfect. Life happens and unforeseen circumstances occur…that is life. It is about how quickly you make those micro-adjustments and continue moving forward to service your clients. Document all your adjustments, issues and changes. This will help support your firm’s ability to adapt and adjust as necessary.
Communication when working remotely
We can’t emphasize enough the importance of communication. As a firm that is already 100% remote, we (SEC Compliance Solutions) have developed some strong habits and tools to effectively collaborate while working in different parts of the country. Technically it is business as usual for us the only difference is some of us have all our kids at home (but that’s an entirely different article!). Here are some tips that we have utilized:
- The easiest and most straight forward tip is pick up the phone – make a habit of connecting with your colleagues on a daily basis. Working remotely can be isolating and sometimes it’s hard to maintain motivation. By checking-in socially, you keep that personal connection and can help colleagues adjust their workflow if they are stuck or having a hard time
- Use apps (we use Zoom – there are others out there) to video conference a team for items such as best execution meetings, investment committee meetings, and record them if possible
- Use apps (we use Microsoft Teams and GoToMeeting – again you can research others) to share screens and work on projects together while remote
- Set regular team meetings on the calendar to touch base and maintain momentum for workflow and projects – we have found at least weekly works to discuss clients and workflow
It is of our opinion, that once the dust settles, firms will start getting an influx of questions, due diligence reviews, and SEC requests about how they responded to the COVID-19 pandemic (if you haven’t already). Our suggestion is to be prepared and use this time to document how your firm responded to the pandemic by:
- Outlining Outline in order the steps taken (i.e. server changes, purchase of additional equipment, setting up employees to work remotely).
- Documenting any issues that occurred and how your firm responded (i.e. VPN was overloaded, employees didn’t have equipment, proper technology wasn’t in place, reduction in staff).
- Documenting your review of critical third-party vendors or service providers, including a) the providers preparedness and b) if there were any concerns, issues, or delays as a result of the pandemic.
- Documenting training provided to staff and protocol established if the work environment has changed (i.e. working remotely).
These are definitely interesting and strange times, but like any challenge, an opportunity to learn and grow. Use this time to persevere and differentiate yourself from your competitors. Respond and react timely and don’t be afraid to try and work differently. Don’t forget to DOCUMENT…so you are ready to support your firm’s response to this pandemic. Most importantly, stay safe and healthy.