June 30, 2009
Rule (3510)4370 - Business Continuity Plans and Emergency Contact Information.
In the above rule, section (f)(1) states that each member shall report to FINRA two emergency contact persons and each person must be a member of senior management and a registered principal of the member.
I would recommend that only one person be required to be a registered principal. There may be situations where perhaps the best contact person may not be a registered principal but rather a Financial and Operations Principal or a technology manager. The purpose of this rule is for FINRA to be able to contact individuals for business continuity purposes. The person that is most knowledgeable on computer systems and business continuity issues may be someone other than a registered principal.
Thank you.