As the government fully gears up for testing for the Coronavirus, the number of reported cases will likely explode. That is when the panic will begin and the need for your Coronavirus Business Continuity Plan will be the greatest.
The Federal Bank Regulatory agencies have not provided any recent guidance related to an appropriate response to a pandemic. Previous guidance from the agencies on this topic includes:
- Influenza Pandemic Preparedness: Interagency Advisory, OCC Bulletin 2006-12, March 15, 2006;
- FFIEC BCP IT Exam Handbook (2/2015);
These resources, while dated, still provide valuable guidance on responding to a wide-spread health crisis.
More up-to-date guidance for a specific response to the Coronavirus (COVID-19) are available from other federal government agencies. This guidance is specific to the Coronavirus, but is not specific to the banking industry.
We expect the bank regulatory agencies to weigh in on this topic in the near future.
To assist financial institutions in the development of, or the retooling of, an appropriate plan to respond to the spread of the Coronavirus, Compliance Resource has scheduled a 60 minute webinar, entitled Pandemic Planning – Is Your Bank Prepared for Monday March 23, 2020 at 11:00 a.m. EDT. For more information or to register for the program click the above link.