FFIEC updates pandemic guidance in response to coronavirus Posted by AVCU on 9:01 AM

The Federal Financial Institutions Examination Council (FFIEC) has updated its guidance on planning for a pandemic, which includes actions that financial institutions should take to minimize the potential adverse effects. CUNA’s CompBlog contains information on this and other guidance released by regulators related to the coronavirus.

Specifically, an institution’s business continuity plan(s) (BCP) should address pandemics and provide for a preventive program, a documented strategy scaled to the stages of a pandemic outbreak, a comprehensive framework to ensure the continuance of critical operations, a testing program, and an oversight program to ensure that the plan is reviewed and updated.

The pandemic segment of the BCP must be sufficiently flexible to address a wide range of possible effects that could result from a pandemic, and also be reflective of the institution’s size, complexity, and business activities.

A financial institution’s BCP should provide for:

• A preventive program to reduce the likelihood that an institution’s operations will be significantly affected by a pandemic event, including:
• monitoring of potential outbreaks,
• educating employees,
• communicating and coordinating with critical service providers and suppliers, in addition
• to providing appropriate hygiene training and tools to employees.

• A documented strategy that provides for scaling the institution’s pandemic efforts so they are consistent with the effects of a particular stage of a pandemic outbreak, such as the six intervals described by the Center for Disease Control and Prevention (CDC). The strategy will also need to outline plans describing how to recover from a pandemic wave, proper preparations for any following wave(s) and plans for re-entering personnel into the workplace;

• A comprehensive framework of facilities, systems, or procedures that provide the organization the capability to continue its critical operations in the event that large numbers of the institution’s staff are unavailable for prolonged periods. The framework should consider the impact of customer reactions and the potential demand for, and increased reliance on, online banking, telephone banking, ATMs and call support services;  

• A testing program to ensure that the institution’s pandemic planning practices and capabilities are effective and will allow critical operations to continue; and

• An oversight program to ensure ongoing review and updates to the pandemic plan so that policies, standards, and procedures include up-to-date, relevant information provided by governmental sources or by the institution’s monitoring program.