As the Global Pandemic COVID-19’s impact continues to grow there are a few things Investment Managers should consider while keeping business flowing.
In addition to being fully transparent to clients on how this situation is specifically impacting your business practices, the following tips are helpful for business continuity and risk management.
- Awareness of Liquidity Management Rules that Apply to Funds: If you are managing a Mutual Fund, check the details of your Liquidity Risk Management Program. If liquid assets become less liquid in a short time frame CCOs should review and prepare their options moving forward. Review of governing documents and contact with Valuation firms should be used to decide the next steps that would be taken in that event.
- Frequent Communication: Firm’s should consider having scheduled and/or ad hoc teleconferences with the entire staff to ensure continuity of business lines and provide a medium to communicate potential issues and the status of action items. In addition, individual teams within the organization (e.g., Investment Team), should consider having regularly scheduled meetings.
- Use of New Mediums to Communicate: With many Firms instituting work from home mandates to its employees, CCO’s should consider new mediums that may be utilized to communicate internally and/or externally that are not being currently archived. For example, Advisors may be texted messaged by clients nervous about the market, against firm policy. In addition, employees may be now communicating through Zoom Chat and/or other instant messaging that is not currently being archived. CCO’s should consider reminding employees and ensuring that business communications are properly archived.
- Preparing for Efficiency Working from Home: We suggest that those working from home have access to backup in case Wi-Fi goes out to limit disruptions and keep work flowing. Cellular Data would be a backup to weak Wi-Fi connections. Having access to a landline for long conference calls also makes for efficiency.
- Keep Up to Date with Filing Requirements: CCOs should be up to date on their filing requirements and how they will meet those requirements given the circumstances. Refer to our blog post on the ADV and PF Form Filing extension announced by the SEC to learn more.
- Confirm Business Continuity with Third Parties: Check in to see how your service providers such as Lawyers, Brokers, and Accountants are keeping their processes flowing. Make sure they are able to assist you as needed during this time and set plans for adjusting to changes in those services if necessary.
- Privacy Policies: With working from home employees may encounter privacy issues when using personal computers or cell phones. Making sure everyone is on top of security policies and confidentiality rules is key.
- Testing your BCP: Testing your Business Continuity Process early on is key to avoiding setbacks down the line. Making sure you have the ability to convert to backup personnel is extremely important in situations like this. Make sure to test your process and solve issues that arise so changes can be made. If you are working remotely, use this as an opportunity to formally document your annual BCP Test. The ability to implement WHO and CDC recommendations in a timely fashion is crucial.
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