Business Continuity Plan Template for RIAs
Advisers Act Rule 206(4)-7 and fiduciary duty
Which functions are critical and how fast each must come back, how a disruption is classified and the plan activated, who backs up whom, and how the plan is tested.
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What the rule requires
No SEC rule specifically requires an adviser's business continuity plan. The Commission's 2016 proposal to require one was never adopted. The Commission has said since 2003 that it expects an adviser's compliance policies under Rule 206(4)-7 to address business continuity, and its fiduciary duty means clients should not be harmed because the adviser cannot operate.
Examiners regularly ask for the plan, when it was last tested, and how the firm would handle the loss of a key person.
What the policy covers
The sections of Luna's model Business Continuity and Disaster Recovery policy. Your draft includes only the clauses that apply to your firm.
- 1Purpose and responsibility
- 2Operating model and critical functions
- 3Incident classification and activation
- 4Communications
- 5Technology, data and records
- 6Service providers
- 7Key personnel and transition
- 8Testing, training and review
What Luna asks you
A few of the questions that shape the draft:
- Who coordinates the plan, and who stands in for them
- The firm's critical functions and how long each can be down
- Whether the firm works remotely, in an office, or both
- How often data is backed up
How drafting works
- 01Answer questions about your firm
Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.
- 02Luna drafts the policy
Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.
- 03Review what is left
Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.
- 04Edit, approve and roll out
It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.
Read the source
Other policies
A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.