Compliance Blog

Yesterday, the FFIEC published guidance on pandemic planning.  Read their press release here.  Read the actual guidance here. 

The guidance indicates that a credit union's business continuity plan should include:

1. A preventive program to reduce the likelihood an institution’s operation will be significantly affected by a pandemic event;
2. A documented strategy that provides for scaling pandemic efforts commensurate with the particular stages of a pandemic outbreak;
3. A comprehensive framework of facilities, systems, or procedures to continue critical operations if large numbers of staff members are unavailable for prolonged periods;
4. A testing program to ensure the institution’s pandemic planning practices and capabilities are effective and will allow critical operations to continue; and
5. An oversight program to ensure ongoing review and updates to the pandemic plan.

The guidance builds upon NCUA Letter to Credit Union 06-CU-06, which you can access here.

Note that item number 4 addresses the need for testing.  For those who took part in the recent financial services pandemic exercise, be sure to document your efforts.  For those who did not take part, you can download the exercise here and run through it at your credit union. 

The FFIEC guidance has a great listing of pandemic-related resources that should be useful.