The Investment Dealers Association of Canada has published a notice that sets out the current wisdom on planning for a possible pandemic, stressing to firms that their planning for a pandemic should be much different from preparations to deal with other types of possible emergencies.

It notes that IDA members are seriously considering the potential for a pandemic, and what, if any, guidelines they should follow in preparation for such eventuality in terms of their Business Continuity Plans. “In the end, it is up to the member to tailor their planning effort to their particular business model and customer needs, and should remain informed about development of this issue,” it says.

IDA by-laws mandate that members have adequate BCPs in place that would enable prompt client access to their assets following a significant business disruption. The BCP Development Guidelines document outlines the framework of such plans while leaving the details to the individual member to work out the details.

“Members should consider, nonetheless, whether their existing plans for enabling prompt clients’ access to their assets following a SBD will be viable under a potential pandemic. In dealing with a pandemic, members will find that they might need to modify the business continuity plan solutions established to primarily deal with infrastructure issues,” it advises.

“While there is no certainty that a pandemic will occur, experts agree that it is best to be prepared for one as and when it does. A pandemic is quite different from other disasters or disruptions in that it is not going to happen suddenly or overnight. It is a disruption that is going to develop over time, for extended periods and in successive waves,” the notice adds.

It also points out that business continuity planning assumptions to cope with a pandemic are very different from those used in infrastructure disaster recovery planning scenarios. “The underlying assumption in normal continuity planning is often that such disruptions will be short-lived, measured in days rather than weeks or months and likely to affect infrastructure. Planning for such events often involves putting up staff in alternate locations, a solution that may not be feasible for a prolonged disruption. A pandemic will most impact the human resource component of your business and is likely to be of a much longer duration,” it suggests.

The notice refers firms to https://www.fsscc.org/reports/2006/avian_flu.jsp where the Financial Services Sector Coordinating Council provides an excellent guide for businesses in the financial services industry looking to prepare for a pandemic.

“Endorsed by the Securities and Exchange Commission, the document offers links to organizations, such as the World Health Organization, who are monitoring the pandemic situation, as well as “Issues for Consideration” when reviewing business continuity plans. The paper is intended to assist financial services firms in thinking through and addressing the issues for their specific organization posed by the potential for a pandemic,” it says.

The IDA also indicates that it anticipates that, in the event of a pandemic or other serious public health emergency, a flexible approach to regulatory requirements will be appropriate. “Some of the areas of potential regulatory relief are likely to include filing requirements, registration requirements, supervision and operational requirements. The IDA has consulted with members and is currently developing a by-law proposal for regulatory relief that would deal with pandemics,” it says.