Comments for the Draft Interagency White Paper
A key issue in this paper is the recognition that the failure of one participant in a financial transfer system or financial market to meet its required obligations will cause other participants to be unable to meet their obligations when due, causing significant liquidity or credit problems and threatening the stability of financial markets. Simply put, the financial system is only as strong as its weakest link.
Without the establishment of minimum industry-accepted standards, investments in disaster recovery sites of hundreds of millions of dollars could be negated by a critical link institution just going through the appearance of having highly reliable sites, thus putting the entire financial system at risk.
To alleviate that risk, high-reliability goals of these back up facilities need to be established. Our company, EYP Mission Critical Facilities Inc, provides critical infrastructure design and/or operations support major financial institutions, several top brokerage houses, trading houses, as well as many other fortune 500 companies. Reflecting upon our experiences from both the design (over 12 million sq/ft of raised floor) as well as the operations side, we are keenly aware of the wide range of capabilities of disaster recovery facilities. To ensure that these facilities can meet the expected reliability requirements, industry-accepted guidelines and methodologies need to be established. Having developed several site assessments for disaster recovery facilities for our clients, some of the recurring macro elements that our clients have determined to be important and can form a basis for establishing new guidelines are shown below:
1) Define the commissioning and maintenance testing requirements in a systematic, accountable format that will assure that the back-up facilities are always ready to accept the burden for which they are intended.
2) Create a methodology that would facilitate clear, consistent reliability benchmarks by which facilities could be evaluated to pave the way for a verification criteria relating to regulatory compliance.
3) Establish validation criteria to assure local labor pools as well as labor in outsourced facilities (operated by others) have a sufficient competence level to sustain the operation to the level required.
4) Create a matrix that would facilitate the evaluation of a site to function in a " wide-scale regional disruption" and be able to operate at the reliability level required until the original site can be restored to operation.
5) Evaluate the economic impact of these requirements in relation to current practices and programs in place. Applying this analysis industry-wide could help determine if federal funding or other sources of revenue would be needed to bring the entire industry into compliance in a meaningful way.
6) Create a performance specification type document for a recovery site that would address issues such as:
Accomplishing all of the above thru comment cycles and consensus may not fit into the timetable and the sense of urgency this document implies. Perhaps this entire process could be jump-started by establishing criteria that could immediately be used to determine if recovery plans and facilities now under consideration would meet the new guideline and establish a yardstick by which these plans could be reviewed. This guideline could then be put out for comment in a much more focused and logical process that reflects the time response needed. If this issue is not handled in an appropriate manner, it could very well slow down recovery site capital investment, since without compliance standards, financial entities understand that moving ahead and spending money would not necessarily be wise.