Guidance on Pandemic Planning

Dear Board of Directors:

Pandemic planning presents unique challenges to credit unions unlike most natural or technical disasters and malicious acts. The impact of a pandemic is much more difficult to determine because of the difference in the scale and duration of a pandemic event. As a result of these differences, credit unions need to plan for the potential adverse effects of a pandemic event. Experts believe the most significant challenge may be the severe staffing shortage likely to result from a pandemic outbreak.

To assist credit unions’ pandemic planning efforts, the NCUA and other Federal Financial Institutions Examination Council (FFIEC) member agencies¹ have developed the enclosed Pandemic Planning guidance which will also be incorporated into the FFIEC Information Technology Booklet – Business Continuity Planning. The guidance addresses the need for credit unions to establish plans to manage a pandemic event. The business continuity plan should include:

• A preventative program to reduce the likelihood the operations will be significantly affected by a pandemic event;
• A documented strategy which provides for scaling pandemic efforts;
• A comprehensive framework of facilities, systems, or procedures to continue critical operations if  large number of staff are unavailable for prolonged periods;
• A testing program to ensure the pandemic planning practices and capabilities are effective; and
• An oversight program to ensure ongoing review and updates are made to the pandemic plan.

Credit unions should review and revise their continuity plans in a timely manner to properly address the management of a pandemic event.

If you have any questions or concerns, please contact your NCUA Regional Office or State Supervisory  authority.