A little while ago, NAFCU blogged about the NCUA’s business continuity planning guidance and the Federal Financial Institutions Examination Council’s (FFIEC’s) 2007 Pandemic Planning Guidance. In light of the spread of Covid-19 a.k.a. the coronavirus, the FFIEC updated its Interagency Statement on Pandemic Planning (the guide), identifying “actions that financial institutions should take to minimize the potential adverse effects of a pandemic.” In a related press release, the federal financial institution regulators encouraged financial institutions, including credit unions to continue meeting the financial needs of members affected by coronavirus.
The guide begins with a discussion of the unique challenges presented by a pandemic in comparison to other disasters. The guide then explains how to incorporate pandemic risk into a credit union’s business continuity management, including the business impact analysis, the risk assessment, and risk monitoring and testing. Let’s briefly touch on each phase:
The Unique Challenges of a Pandemic
In order to effectively serve members, it is important to tailor a credit union’s traditional business continuity plan (BCP) to address the unique challenges posed by a pandemic. The guide explains that a credit union’s BCP should provide for:
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