Singapore Exchange proposes BCM rules

Singapore Exchange (SGX) has issued proposed business rules on business continuity for public comment. The rules are likely to take effect for member firms in third-quarter 2008, and firms would have 12 months to comply. Member firms were briefed on the new rules in April.

SGX operates and regulates integrated securities and derivatives exchanges. Like many Asian exchanges, SGX is a publicly-traded (demutualized) entity--the shareholders, not the member firms, own it. These are SGX's derivatives market members (32 trading or clearing firms) and these are the securities market members (27 firms).

If the guidelines were adopted, member firms would be required to:

1. Assess their risks, complete business impact analyses (BIA's), and take "appropriate BCM (business continuity management) measures to mitigate the risks";
2. Make a senior officer responsible for BCM;
3. Review and test their plans regularly, and participate in financial sector exercises; and
4. Designate and submit emergency contacts

These are not onerous requirements, and many of the member firms already have BCM programs in place. But it's taken some time and effort to promulgate appropriate guidelines. SGX is both the market operator and the regulator, and so considers--in its rule-making decisions--its commercial interests (and those of its members) alongside its fiduciary responsibilities (and those of its members).

So there is no explicit requirement for member firms to maintain backup sites, for example, nor any specified RTOs (Recovery Time Objectives), RPOs (Recovery Point Objectives) or MORs (Minimum Operating Requirements). Just widely-accepted, non-controversial good governance guidelines. I know of no "pushback" from member firms.

Some member firms probably need a push to pay more attention to business continuity. The release of the BCM business rules is certainly well-timed for the financial sector influenza exercise ("IWE") coming up in August and September, in which member firms are encouraged to participate.

The comment period on the proposed BCM business rules ends May 22nd. If you have comments, send them to rules@sgx.com.

Disclosure: The blogger's company is a business continuity, emergency and crisis management consultant to SGX.

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Nathaniel Forbes

Nathaniel Forbes is the director of Forbes Calamity Prevention, a Singapore-based consulting firm providing business continuity, crisis management and emergency response advice and training to multinational companies, with a focus on companies with offices in Asia. The firm is 10 years old. FCP's current and past clients include Singapore Exchange Ltd, OCBC Bank, AXA Insurance, The Gillette Company, Siemens and ABN Amro Bank. A former President of the Singapore Computer Society’s Business Continuity Group, Nathaniel passed the DRII’s Certified Business Continuity Planner (CBCP) examination in 1997. He has lived, traveled or worked in Asia since 1973.