The Federal Financial Institutions Examination Council (FFIEC) issued guidance today for use by financial institutions in identifying the continuity planning that should be in place to minimize the potential adverse effects of a pandemic. This guidance expands upon the contents of the Interagency Advisory on Influenza Pandemic Preparedness issued in March 2006.¹

Pandemic planning presents unique challenges to financial institutions. Unlike most natural or technical disasters and malicious acts, the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration. As a result of these differences, no individual or organization is safe from the potential adverse effects of a pandemic event. Experts believe the most significant challenge may be the severe staffing shortages that will likely result from a pandemic outbreak.

The Federal Reserve and the other FFIEC agencies believe the potentially significant effects a pandemic could have on an institution justify establishing plans to address how each institution will manage a pandemic event. Accordingly, an institution’s business continuity plan should include:

1. A preventive program to reduce the likelihood that the institution’s operations will be significantly affected by a pandemic event;
2. A documented strategy that provides for scaling pandemic efforts commensurate with the particular stages of a pandemic outbreak;
3. A comprehensive framework of facilities, systems, or procedures to continue critical operations if large numbers of staff members are unavailable for prolonged periods;
4. A testing program to ensure that the institution’s pandemic planning practices and capabilities are effective and will allow critical operations to continue; and
5. An oversight program to ensure ongoing review and updates to the pandemic plan.

Federal Reserve Banks are asked to distribute this letter to banking organizations supervised by the Federal Reserve, as well as to their own supervisory and examination staff. If you have any questions, please contact Brad Beytien, Manager, Operational and IT Risk Section, at (202) 452-3759 or Mary Frances Monroe, Manager, Supervisory Policy and Guidance at (202) 452-5231.

Attachment:

Interagency Statement on Pandemic Planning (50 KB PDF)