On March 6, 2020, the Federal Financial Institutions Examination Council updated guidance identifying actions that financial institutions should take to minimize the potential adverse effects of a pandemic. The guidance provides the FFIEC’s expectations that regulated institutions should periodically review related risk management plans, including continuity plans, to ensure their ability to continue to deliver their products and services in a wide range of scenarios and with minimal disruption.
The new guidance is an update to the 2007 Interagency Statement on Pandemic Planning as well as 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, as well as the “Letter to Credit Union 06- CU-06 - Influenza Pandemic Preparedness” issued by the National Credit Union Administration in March 2006.
The new guidance also identifies actions that financial institutions should take to minimize the potential adverse effects of a pandemic. Specifically, the FFIEC states that an institution’s business continuity plan (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.
The full FFIEC guidance can be found here.
