Lynn Woosley is a Senior Director with Treliant. She is a seasoned executive with extensive risk management experience in regulatory compliance, consumer and commercial credit risk, credit and compliance risk modeling, model governance, regulatory change management, acquisition due diligence, and operational risk in both financial services and regulatory environments.
- Source: ffiec.gov
Treliant knows business continuity. If you need assistance with assessing and managing your disaster recovery risk, or determining the impact of this guidance on your firm’s activities, Treliant can help.
On March 6, 2020, the Federal Financial Institutions Examination Council (FFIEC) updated its guidance on steps financial institutions should take to mitigate the impact of a pandemic on the banking sector. The statement updates the 2007 Interagency Statement on Pandemic Planning issued December 12, 2007; the Interagency Advisory on Influenza Pandemic Preparedness” issued on March 15, 2006, by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision; and the “Letter to Credit Union 06-CU-06 – Influenza Pandemic Preparedness” issued by the National Credit Union Administration in March 2006.
To adequately cover the unique challenges of a pandemic, the FFIEC recommends institutions should ensure their business continuity plans include the following five components:
- A preventative program that includes monitoring of potential outbreaks, educating employees, communicating updates, coordinating with critical third parties, and providing hygiene training and tools to staff.
- A documented strategy where the institution’s response is consistent with the stage of the pandemic outbreak, including considering waves of disease spread and returning personnel to the workplace.
- A comprehensive framework of systems, facilities, and procedures to continue critical operations during prolonged instances of very high (40 percent or greater) absenteeism.
- A testing program to ensure planning and preparations are effective and will permit continuation of critical operations.
- An oversight program to ensure the pandemic plan includes up-to-date, relevant information from reliable sources.
The guidance also summarizes the phases of planning for pandemic and other business continuity issues. It also provided guidance on board and senior management responsibilities and incorporating pandemic preparedness into business impact analysis, risk assessment, risk management, and risk monitoring. The interagency pandemic preparedness guidance references several governmental resources that may be useful in planning for pandemic events:
- Center for Disease Control and Prevention (CDC) information on the Pandemic Interval Framework
- CDC National Strategy for Pandemic Influenza and the associated Implementation Plan for the National Strategy for Pandemic Influenza
- S. Department of Health and Human Services Pandemic Influenza Plan
- Checklists and other tools provided by the CDC
- S. Department of Labor Occupational Safety and Health Administration (OSHA) Guidance on Preparing Workplaces for an Influenza Pandemic
- S. Department of Veterans Affairs Pandemic Influenza
- World Health Organization Coronavirus Disease Outbreak