SIFMA said a firm with a single office and few employees should not be required to have in its business continuity plan an alternative physical location that is far enough away from the range of a major storm such as Hurricane Sandy.

Another burden on the industry cited by SIFMA is the regulations could impose conflicting standards in continuity planning on a single company by the SEC, FINRA and the Commodity Futures Trading Commission

SIFMA said that when an advisor leave a business, the impact to investors is minimal because advisors are highly substitutable.

ICI questioned the overall need for a major set of rules in this arena.

“There is precious little evidence of adviser transitions that have harmed clients,” the mutual fund industry association said.

The SEC has estimated a business continuity and transition plan would cost an advis0r $30,000 to $1.5 million to develop, with ongoing annual costs of $7,500 to $375,000 depending on the size of the operation.
 

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