The Federal Financial Institution Examination Council (FFIEC) agencies are issuing guidance on the need to update business continuity plans considering the threat of a pandemic outbreak of the Coronavirus. The National Credit Union Administration (NCUA) issued FFIEC Highlights Pandemic Preparedness Guidance. The Federal Deposit Insurance Corporation (FDIC) issued FIL-14-2020 Interagency Statement on Pandemic Planning. The Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2020-13 Pandemic Planning: Updated FFIEC Guidance. Each agency advises financial institutions to take steps to ensure their business continuity plans address a pandemic outbreak and the steps the financial institution will take to continue to deliver products and services. Pandemic planning is different than typical business continuity planning and financial institutions must understand the unique challenges of pandemic planning and respond accordingly. The FFIEC outlines five steps it expects a financial institution to take for a pandemic business continuity plan:

  1. A preventative program
  2. A documented strategy
  3. A comprehensive framework of facilities, systems or procedures
  4. A testing program
  5. An oversight program to ensure ongoing review and updates


John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at