On December 12, 2007, the Federal Financial Institutions Examination Council (FFIEC) issued guidance for incorporating response plans for pandemic outbreaks into the overall business continuity programs for all regulated financial institutions.

Highlights

The FFIEC specifies five (5) key areas that should be incorporated into a financial institutions business continuity program to address the adverse effects of a pandemic.

1. Prevention including: employee awareness and hygiene training, monitoring of potential outbreaks, coordination with key service providers and employee education of the institution's response plan.
2. Documented strategy for responding to various stages of an outbreak.
3. Comprehensive framework of facilities, systems and procedures to continue critical business operations in the event large numbers of staff are unavailable for prolonged periods. The framework should consider fluctuations in customer demands and reliance on online banking, telephone banking, ATMs and call support services.
4. Testing to ensure pandemic planning practices and capabilities are effective and will allow critical operations to continue.
5. Management Oversight to ensure the plans stay up-to-date and incorporates information provided by governmental sources.

Below are links for more information:

FFIEC Press Release on Pandemic Planning
Interagency Statement on Pandemic Planning

How Assurity River Group Can Help

Assurity River Group has worked with dozens of organizations to adjust the BC program to address pandemic. Below are some ideas and ways that we have worked to help our clients:

1. Tabletop Exercise using pandemic scenario - An excellent way to increase pandemic preparedness awareness is to conduct an exercise with the BCP and management teams to walk-through the likely "waves" of a pandemic outbreak and discuss the decisions that need to be made. Assurity River will facilitate a tabletop exercise using a pandemic outbreak scenario and provide an assessment report that documents our findings and follow-up items.
2. Re-assess Business Impact Analysis (BIA) and Risk Assessment - Many companies have already completed a BIA that identifies critical business functions and acceptable levels of downtime during a business interruption. But, a pandemic event puts a new twist on things. For example, your facilities and systems may be operational but key employees may not be available or cannot come to work. There may also be a fluctuation in demand for your companies' services or those of specific business units in during an outbreak (e.g. a run on cash for a bank). Assurity River can assist in re-assessing your BIA to identify the business processes that would be critical in this scenario and the business risks associated with responding to this event.
3. Create "Pandemic Addendum" to incorporate into BCP - Financial institutions are considered one of the pillars of critical infrastructure defined by the Department of Homeland Security and are required to have plans in place that describe how they will manage through a pandemic event. However, because of the uncertainties and unknowns, this plan must be flexible to make changes as events unfold. Assurity River utilizes a practical approach for pandemic planning and will work with you to create an addendum for your existing BCP that outlines the key decisions and tasks that need to be completed to continue operations.

Contact Jeff Olejnik (jolejnik@assurityriver.com) at 651.259.6888 for more information, or visit our website at www.assurityriver.com.