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What business-continuity plans does a multifamily office have for disasters or outages?

Short answer

A multifamily office should maintain written procedures for keeping essential services running during disasters, cyber incidents, power failures, illness, or vendor outages. Plans typically cover staff roles, alternate work locations, secure data backups, communication channels, critical vendors, client records, and recovery testing. Registered investment advisers should address business continuity within their compliance programs.

What the plan covers

A good plan starts by identifying essential functions, such as communicating with families, monitoring accounts, processing approved payments, maintaining records, and coordinating with custodians. FEMA defines essential functions as activities that must continue during a disruption, with supporting staff, systems, information, equipment, and facilities identified in advance. FEMA Continuity Guidance Circular

The office should assign decision makers and backups. The plan should state who can activate it, who communicates with each family, and who works with banks, custodians, insurers, technology providers, and outside advisers. It should also define how the office returns to normal operations after the event.

Technology, records, and communications

Technology planning should address secure data backups, recovery of critical systems, alternate equipment, manual workarounds, and an alternate work location. NIST describes contingency planning as coordinated plans, procedures, and technical measures for recovering information systems, operations, and data after a disruption. NIST Contingency Planning

Communication plans should include alternate methods for reaching staff and families if email, phones, offices, or a shared platform fail. The office should keep current contact information and explain how clients will receive verified instructions. Staff should know how to identify suspicious requests during a crisis, especially payment or wire instructions.

Within a year of starting a single family office, standard processes should be developed so that each team member could be replaced by another professional and that new person should be able to quickly understand what is going on and how the work was being carried out.

Richard C. Wilson, Family Office ClubThe Single Family Office, a book by Richard C. Wilson

Testing and regulatory expectations

Plans need regular review and practical exercises. Testing can reveal outdated contacts, missing permissions, weak vendor dependencies, and recovery steps that work on paper but fail under pressure. The SEC has identified alternative locations, key vendors, telecommunications, communication plans, and testing as areas investment advisers should consider in business-continuity and disaster-recovery planning. SEC Risk Alert

SEC-registered investment advisers must adopt and implement written compliance policies reasonably designed to prevent violations of the Advisers Act. SEC staff has identified business continuity and disaster recovery as areas advisers should address in their planning. SEC Compliance Programs Rule

Families should ask to see the office’s continuity summary, understand how communications are authenticated, and confirm how the office coordinates with custodians and other providers during an outage.

Sources

  1. FEMA Continuity Guidance Circular
  2. NIST Contingency Planning
  3. SEC Risk Alert on Investment Advisers’ Business Continuity and Disaster Recovery Planning
  4. SEC Compliance Programs of Investment Companies and Investment Advisers

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