Business Continuity Plan Template 2 - Free Download
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Business Continuity Plan Template for
Small Introducing Firms
Business Continuity Plan (BCP)
Updated May 12, 2010
This optional template is provided to assist small introducing firms in fulfilling their need
to create and maintain business continuity plans (BCPs) and emergency contact person
lists under FINRA Rule 4370 (Business Continuity Plans and Emergency Contact
Information). The template recognizes that many small introducing firms rely on parts of
a clearing firm’s or other entity’s BCP for many of the mission-critical functions of the
introducing firm. Nothing in this template creates any new requirements on clearing firms
or other entities, or new requirements for BCPs.
Note: Following this template does not guarantee compliance with or create any safe
harbor with respect to FINRA rules, the federal securities laws or state laws. The
obligation to develop a BCP is not a “one-size-fits-all” requirement, and you must tailor
your plan to fit your particular firm’s situation.
FINRA Rule 4370(c) requires that firms relying on another entity for elements of their
BCP or mission-critical systems must address that relationship in their plan. This
template is written for small introducing firms that use a clearing firm, and includes
sample language regarding the nature of that particular relationship only. If your firm
conducts a different type of business (e.g., sells only mutual funds), you must modify the
template to describe the entities you rely on and the nature of those relationships.
The language contained in this template is provided as a starting point for developing
your firm’s plan. It is highly unlikely that the language of this template standing alone
will fully fit your firm’s business situation. In this regard, you must customize the
language of this template to reflect your firm's activities and issues. If you have prepared
a plan in a different format, you may wish to attach the appropriate sections of that plan
to this template to confirm that you have addressed all of the individual elements.
There are 10 critical elements of a BCP specified in FINRA Rule 4370. Each firm need
only address the elements applicable to its business, but if you do not include a specified
element in your firm’s plan, your plan must document why it is not included: