Pandemic Preparedness and Financial Institutions

The Novel Coronavirus (aka COVID-19) has riveted the attention of the entire world. To address this risk to both our nation’s physical and financial health, the Federal Financial Institutions Examination Council (“FFIEC”) recently published an Interagency Statement on Pandemic Planning. This statement provides guidance on business continuity management plans and identifies specific actions that a Financial Institution should take to mitigate the effects of a pandemic. Key points include:

  • Directors and officers are responsible for Pandemic Planning and for overseeing the implementation of the Plan’s policies and procedures.
  • A business impact analysis should be developed that evaluates the effect of a pandemic on various business functions and make plans to address that impact.
  • A financial institution should coordinate closely with third parties upon which it relies for vital services. This should include local, state and federal public health and emergency management teams.
  • Staffing shortages are likely. Plan to implement modifications to systems and procedures to continue operations, even if large numbers of staff are unavailable.
  • Plan for social distancing measures for both staff and customers. Establish work from home procedures and prepare for increased online banking activity.
  • Test and evaluate plan procedures. Be prepared to incorporate new information in real time.

The guidance from FFIEC provides concrete information about expectations for financial institutions with respect to Pandemic Planning. We urge your staff to read the Statement and to perform an assessment of existing plans in light of this guidance.

Meanwhile, if you have any questions about this topic from an insurance standpoint, please contact your agent, broker or underwriter, and we would be happy to explore it further with you.


This information provides guidance and is not intended as a legal interpretation of any federal, state or local laws, rules or regulations. ABA Insurance Services Inc. (“ABAIS”) does not warrant that all potential hazards or conditions have been evaluated or can be controlled. The liability of ABAIS and its affiliates is limited to the terms, limits and conditions of the insurance policies issued by ABAIS. 032020.SA3 © ABA Insurance Services Inc., dba Cabins Insurance Services in CA, ABA Insurance Services of Kentucky Inc. in KY, and ABA Insurance Agency Inc. in MI, 3401 Tuttle Rd., Suite 300, Shaker Heights, OH 44122. CA license #0G63200