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FOS Blog

28 Feb

Time to dust off that Pandemic Plan

Time to dust off that Pandemic Plan

Federal officials in the US have started warning of the spread of coronavirus in the U.S., some officials have noted that it’s no longer a question of if, but a matter of when. While the immediate threat to the public in the U.S. remains low at this point in time, appropriate planning is being recommended. While most institutions have created a pandemic plan, as required by the regulatory agencies. It is probably safe to say that most have not given the plan considerable and performed limited testing around its use in 2020.

As noted in the FFIEC guidance Pandemic planning presents unique challenges to financial institution management. Unlike natural & technical disasters, malicious acts, and/or terrorist events, the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration. These threats can also usually be mitigated through means of resiliency and recoverability through the use of technology and can be restored or replaced relatively quickly in today’s environment. The most significant challenge will likely come from staffing shortages.

Institutions both large and small need to be prepared for a pandemic, particularly given the heightened threat of coronavirus. As noted in the “Interagency Statement on Pandemic Planning” and Appendix D of Business Continuity Panning Handbook, a pandemic plan should be:

  • A preventive program to reduce the likelihood that an institution’s operations will be significantly affected by a pandemic event.
  • A documented strategy that provides for scaling the institution’s pandemic efforts, so they are consistent with the effects of a particular stage of a pandemic outbreak.
  • A comprehensive framework of facilities, systems, or procedures that provide the organization the capability to continue its critical operations in the event that large numbers of the institution’s staff are unavailable for prolonged periods.
  • A testing program to ensure that the institution’s pandemic planning practices and capacities are effective and will allow critical operations to continue.
  • An oversight program to ensure ongoing review and updates to the pandemic plan so that policies, standards, and procedures include up-to-date, relevant information provided by government sources or by the institution’s monitoring program.

Given the heightened alert state, the warnings from federal officials, and even going as far is the shortage of surgical masks with the coronavirus threat, organizations should take the time to review their pandemic plan. Testing of the plans potential operating effectiveness should be completed regularly. For institutions which have not performed a recent review and test, one should be completed in relatively short order due to the heightened threat of the coronavirus outbreak. The testing and review should include educating employees of the plan, communication and coordination needs with key service providers, ensuring the feasibility of the plan, and the technological components are operating effectively as designed, and ensuring appropriate hygiene related supplies are available (hand sanitizer, surgical masks, etc).

Additional information on the coronavirus can be found on the CDC website:

For additional information contact the author