Compliance Blog

Posted by Anthony Demangone.

From recent press reports, it seems clear that swine flu is a serious matter.  Photos show Mexican citizens wearing surgical masks.  Movie theaters, soccer matches, and other public gatherings have been closed. Almost 100 Mexicans have died from the flu so far.  And cases have been reported in Texas and New York.  Here's some information about this:

• The World Health Organization (WHO) has a page devoted to Swine Flu.  You may access it here.
• If your staff has questions, WHO put together this FAQ document.

Why is this a compliance issue?  Because Swine Flu has business continuity planning issues.  While this does not appear to be rising to the level of a pandemic, pandemic-related business continuity plans would be very useful in dealing with this.  With that in mind:

The FFIEC has 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.

I assume your credit union has a pandemic plan in place.  It may not be a bad idea to dust if off and take a look at it.  Also, it is never a bad idea to remind staff about proper hygiene.  Wash those hands.  Cover those coughs and sneezes.