Impact of Interagency Paper on Real Estate Continuity

The Gill premise is rather straightforward. Given the new normal in which we now live, business continuity planning must broaden its scope and incorporate new components such as real estate strategy into its domain. Over the past year, we have carefully monitored the developments of a paper being drafted by the Federal Reserve, the Department of the Treasury, and the Securities and Exchange Commission that will serve as a business continuity planning blueprint for the financial industry in the United States.

The final version of the Interagency paper on sound practices to strengthen the resilience of the US financial system was released in early April, and it specifically discusses the issue of facility backup and redundancy (see pages 10-11 for specifics) "for operations and data centers that do not rely on the same infrastructure and other risk elements as primary backup sites". There are no two ways about it: this is a very important paper, and it will have a significant impact not only on the financial industry, but planning initiatives of large organizations globally.

Although the recommendations set forth in this document are just that, recommendations, we believe that the compromises made in paper over the past year and a half (to satisfy the greatest number of financial industry participants) will likely motivate many in the industry to adopt the major points that are set out. Given the importance of the US financial industry, we also believe that initiatives taken by US financial participants will likely motivate similar actions in the financial industries in many other global markets. We expect this paper to become one of the key drivers of real estate continuity.