For a COVID-19-proof contingency plan
In a matter of days, the financial services industry had to stage nothing short of battle stations in response to the pandemic. "All the ingredients for a perfect storm were in place: offices were no longer accessible and stock markets showed high volatility, leading to a tremendous amount of work with regard to transactions", says Alain Legault, Director of Financial Centre SFL Gestion de patrimoine Nord-Ouest du Québec, in Laval. They had to act very quickly, particularly by implementing telework and ensuring all employees had all the tools required to continue operations.
Training videos were therefore created to help the financial centre’s partner advisors use communication tools like Teams or Skype to meet with clients virtually, for example. Everything was also arranged to keep employees connected, as well as ensure support and group cohesion.
While Alain Legault and his team were able to meet the challenge quickly, the Director concedes that the business continuity plan had not taken into account the possibility of such a situation. "We were ready for an emergency situation, such as a fire, which would have prevented access to our offices. In these conditions, transactions needed to continue through another financial centre, or with our broker, SFL Placements", he explains. But, the whole province was actually paused, making these alternative solutions ineffective.
Four Simple Steps
Because with the COVID-19 pandemic, what were unlikely events did occur. Mtre Pascale Apold, a lawyer specializing in personal insurance and compliance at the law firm Le droit chemin, writes continuity plans and addresses the updating process for these plans in some of the trainings she provides. In fact, she remembers having hesitated to include the epidemic scenario since it seemed unrealistic. "We were thinking more about gastroenteritis or flu epidemics within companies. Or a service interruption caused by external factors like a power outage, a computer-based attack, a storm, flood, etc. We never imagined advisors would have to leave their office without warning and for such a long time!", she says.
Mtre Apold therefore recommends reviewing your contingency plan in light of these events, and to follow four simple steps based on the current reality.
First of all, look at the measures that were recently implemented to maintain activities and take note of the ones missing from the plan. "You should ask yourself what you needed to do to continue operations. For example, did you have access to all your client files and were you able to update them adequately, did you have all the tools, accesses and applications required to do business remotely with insurers, fund houses, etc. These are all relevant questions that need to be answered", she highlights.
Second step: determine the measures that need to be improved or corrected. "You must review your plan in a critical manner and ensure for instance that it addresses epidemics, the issue of health and safety for your team and your clients, as well as the sufficient length of the considered scenarios. Currently, we are finding that many of them are too short", notes Mtre Apold. At this stage, we must also look at how successful staff training and awareness-raising measures are, i.e. those related to communication, but also to record and system access.
Number three, ensure the content of the plan is proofread and required additions are made, including annexes as needed. "In this regard, you may think about a list of required material and an emergency contact list", says Mtre Apold. You will then need to adopt the new plan and share it with the rest of the team and partners.
Finally, the fourth and last step: establish an action plan. "If improvements involving tasks and mid or long term follow-ups are required, implement an action plan with a purpose, action items, a schedule and a manager", lists the lawyer. If it is necessary to scan the client records for example, there should be a set process, to determine an archiving plan, to identify archiving and scanning tools, to train employees, to scan the files, etc. If these tasks take several months, you should set timelines on a case by case basis to assess the progress of the work.
"There is no secret recipe or specific obligations when it comes to content. The most important thing is that it is customized according to your activities and your own unique operations. It may only have a few pages and annexes, as long as it works for you", she assures.
As for Alain Legault, he is currently working on a new version of his financial centre’s business continuity plan. "I expect 80% of the content will need to be modified. From now on, the process for telework implementation will be part of the plan. When you review a contingency plan, you always ask yourself: can this or that type of event ever happen? Now I know the answer is yes…", he concludes.
