EMC Comment on
"Draft Interagency White Paper on Sound Practices to Strengthen the Resilience of the U.S. Financial System"

EMC responds directly to questions raised within section V. ("Request for Comments") of the white paper and specifically addresses the "Recovery and Resumption of Critical Activities" and "Sound Practices" segments of section V. EMC's comments are technology-focused and draw from experience gained in architecting, implementing and servicing business continuity deployments for a majority of the world's largest banks and securities firms.

V. Request for Comments

Recovery and Resumption of Critical Activities & Sound Practices

Comment on Recovery-Time Objective and Material Transactional Data Loss

The agencies identify the remote protection of "material" transactional data as critical to the integrity of operational recovery and resumption following an outage.

Without an explicit recommendation of zero data loss by the agencies, the entire financial system's resiliency is exposed to individual firm's own interpretation of "tolerable" levels of transaction loss. The interdependent chain within the financial system is only as strong as its weakest link. One firm's inability to recover transaction data following an outage will impinge upon every other member of the chain's ability to recover.

Guidance that specifies a recovery-point objective of zero for all material transactional data is specific, achievable, and necessary to accomplish the stated objectives of the paper. Guidance for zero data loss achieves the objectives and prevents financial system exposure to deployments with variable levels of transaction data loss. The process of "systemic recovery" is threatened without a zero data loss specification; which would retard the overall recovery and resumption capabilities envisioned by the agencies.

Comment on Specifying a Minimum Distance for Back-up Facilities

Material transaction data should be protected in real time at a secondary location. However, a specific minimum distance between primary and back-up facilities cannot be established without creating confusion and potentially compromising systemic resiliency. Fundamental technological and performance issues, which vary by firm, prevent the practical application of a specific minimum distance.

The speed of light imposes physical limits that add latency to the Primary operating center as separation distance grows. Members should deploy capabilities consistent with the agencies general guidance, in a manner befitting their specific systems environment, and consistent with available technology.