3 business continuity practices you can deploy today

The best business continuity plan (BCP) is specific, tested and continuously updated. Obviously, it’s much easier to ensure these parameters are met when you’re not in the soup of a fast-evolving pandemic, right? 

Regardless of your current BCP’s level of effectiveness, there are several simple-to-deploy tactics that can have a big impact on keeping your cooperative humming for the financial wellness of members. Here are a few you might consider:

Designate a backup Bank Secrecy Act (BSA) officer: Although the NCUA told credit unions it would not apply examiner criticism to prudent loan term adjustments during the pandemic crisis, the agency and others are certain to continue enforcing regulations, both now and after the dust from the pandemic settles. One of the most costly failures a credit union can make is to miss a FinCEN Currency Transaction Report (CTR) or Suspicious Activity Report (SAR) filing deadline. (As a reminder, CTRs must be filed within 15 days of the reported transaction; most SARs must be filed within 30 days of the initial detection of facts.) 

With school closures, quarantines and remote-work strategies underway, many BSA officers may be out of pocket, causing disruption to a credit union’s typical filling procedures. One simple tactic to consider is to designate a backup BSA officer (or two) who can fill in for the chief BSA officer until work and life are back to normal. 

Balance safety and accessibility at the branch: If closing branch locations becomes necessary, consider ways to increase the availability of services in other ways. One option is to leave one or two centrally located branches open for drive-through services. However, you’ll want to make other options available for members that do not drive (e.g., lobby or front door service). This is also a good time to remind members of your digital capabilities, such as online and mobile banking. 

Distribute frequent communications as your credit union makes decisions that impact service availability. Over-communication is appropriate (and often even appreciated) during a crisis. 

Reallocate human resources to lending: Following the Fed’s action to slash rates to zero, credit union lenders have been inundated with requests from anxious consumers. The rush actually started much earlier; during the week of March 9, refinance applications rose 79 percent compared to the week before — or 479 percent compared to the same time period in 2019.

Whether in the middle of a real estate transaction or seeking potentially huge savings from a timely refi, credit union members will expect their cooperative to act fast. Failing to meet their expectations has reputational risks, but the regulatory risks are just as important. For instance, lenders are required to provide a Loan Estimate (LE) to members within three business days of receiving a mortgage loan application and at least seven business days before consummation. 

To ease the burden on the lending team so they can meet these crucial deadlines, consider redeploying frontline employees to loan processing tasks or administrative support to the chief lending officer and his or her team. Doing so has the potential to reduce stress on busy employees while keeping others gainfully employed and working for the member. 

Every credit union’s BCP, no matter how robust, is under stress at the moment. Rest assured, each failure and hiccup you’re encountering has a silver lining, namely that you are learning. Plans must be tested to be effective, and right now, your credit union is living out one of the greatest BCP tests you’re likely to experience.