Checklist & Workbook: Business Continuity Plan, Includes COVID-19 Pandemic Response - Update # 7

We have updated the Business Continuity Plan Checklist & Workbook, Includes COVID-19 Pandemic Response ("Checklist"). 

I am pleased to announce the publication of Update # 7.

We published the initial Checklist on Monday, March 16th, consisting of 60 pages. Today’s update is 207 pages and contains many new sections, updates, and additional resources.

New sections include outlines and guidelines, as follows:

- Coronavirus Economic Stabilization Act (CESA) 

- Paycheck Protection Program (PPP)

- Paycheck Protection Program (PPP) - Dicta

- Links to State Issuances for Remote Activities

- Business Interruption Insurance - Checklist

The Checklist is being provided on a complimentary basis. It is our view that companies in need of immediate guidance should be able to get it without cost in the midst of a pandemic. 

You can request the most recent version HERE. 

Let’s continue to work together for the benefit of one another, our families, companies, communities, and cherished consumers.

Best wishes,
Jonathan

Jonathan Foxx, Ph.D., MBA
Chairman & Managing Director
Lenders Compliance Group

Webinar: Checklist & Workbook - Business Continuity Plan and COVID-19 Pandemic Response

Announcement

Message from Jonathan Foxx, Ph.D., MBA, 

Chairman & Managing Director

Lenders Compliance Group

We are presenting a Free Webinar, entitled

Navigating the 

Checklist & Workbook

Business Continuity Plan and 

COVID-19 Pandemic Response.

Webinar: Thursday, April 16, 2020, 1PM-ET

     

We pioneered and authored the Checklist &Workbook. 

Now we want to let you know how to navigate it.

This webinar is your chance to learn how to use the Checklist!

Since its publication on March 16^th, we have received thousands of downloads.

The Checklist now consists of 6 Modules and 180 pages!

Demand is going to be high, seating is limited, so register now while there’s still space!

COVID-19 has made us take a close look at this pandemic response in the context of a Business Continuity Plan.

Here’s what you get when you attend Navigating the Checklist & Workbook:

• Update # 6 – new release – you will receive it before anyone else!
• Subject Matter Experts will present critical insights and guidance.
• Written questions during the webinar answered individually after the webinar.
• Slides
• Recording 

As I pointed out, we have limited seating for this event. Please register as soon as possible.

Webinar: Thursday, April 16, 2020, 1PM-ET

Let’s continue to work together for the sake of our companies, employees, and families.

Best wishes!

Lenders Compliance Group issues complimentary Business Continuity Plan Checklist (Includes COVID-19 Pandemic Response)

PRESS RELEASE

Modules directly address the specific requirements needed to maintain business continuity in general as well as provide business continuity during the COVID-19 Pandemic in particular.

Lenders Compliance Group (LCG), the first and only full-service compliance firm with a suite of compliance solutions for residential mortgage lenders and originators, has issued today a valuable tool, entitled Business Continuity Plan Checklist & Workbook (Includes COVID-19 Pandemic Response).

The checklist is a valuable development tool to chart the progress in developing a Business Continuity Plan. This is a 60-page, form-fillable document that provides the basic compliance elements and due diligence essentials at this most critical time in the outbreak of the COVID-19 Pandemic.

There are distinct differences between pandemic planning and traditional business continuity planning. Pandemic planning presents unique challenges. Unlike natural disasters, technical disasters, malicious acts, or terrorist events, the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration.

Lenders Compliance Group is providing the Business Continuity Plan Checklist & Workbook (Includes COVID-19 Pandemic Response) on a complimentary basis to the financial services industry.

There are five modules, as follows:

Module 1: Business Continuity Team

Module 2: Facilities Continuity

Module 3: Recovery Requirements

Module 4: Pandemic Planning for COVID-19

Module 5: Generalized Pandemic Response based on NYS Model

Additional sections, some of which contain subsections, provide:

• Team Alert List
• Employee Call List Instructions
• Critical Vendors List (Sample Format)
• Key Customer Description
• Meeting Place Description
• Model Risk Matrix (Sample Format)

The Business Continuity Plan Checklist & Workbook (Includes COVID-19 Pandemic Response) is meant as a means toward building a functionally adequate Business Continuity Plan. Each financial institution is different and processes will vary. However, management should consider how to accomplish the following:

• Prevention and preparedness;
• Reconciling recovery times with business unit requirements;
• Disaster declaration and plan implementation processes;
• Recovery progress reporting; and
• Testing of the plans.

Lenders Compliance Group has established a dedicated form to request a complimentary copy of the Business Continuity Plan Checklist & Workbook (Includes COVID-19 Pandemic Response) directly from its website Home Page at www.LendersComplianceGroup.com.

Announcement: Interagency Statement on Pandemic Planning

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FFIEC has issued guidance on pandemic planning, entitled Interagency Statement on Pandemic Planning (“Guidance”). This issuance is meant to heighten the response of financial institutions to the coronavirus pandemic. The Guidance identifies actions that financial institutions should take to minimize the potential adverse effects of a pandemic. Specifically, the institution’s business continuity plan (BCP) should address pandemics and provide for a preventive program, a documented strategy scaled to the stages of a pandemic outbreak, a comprehensive framework to ensure the continuance of critical operations, a testing program and an oversight program to ensure that the plan is reviewed and updated.

We have been notifying you on how to protect your companies, customers, employees, families, and communities HERE. Please review those articles and act accordingly. 

If you want to discuss your specific pandemic preparation requirements, please contact us at compliance@lenderscompliancegroup.com.

We believe that Disaster Recovery and Business Continuity should be combined, but, as the Guidance states “pandemic planning activities should involve senior business management from all functional, business and product areas, including administrative, human resources, legal, IT support functions, and key product lines.”

The pandemic segment of the BCP must be "sufficiently flexible to address a wide range of possible effects that could result from a pandemic," and also be reflective of the institution’s size, complexity, and business activities. 

Our position is that there are two types of BCPs: standard and enhanced. 

The standard version lacks due diligence and independent risk assessment but does provide a basic outline to follow to ensure business continuity. 

The enhanced version is preferred by regulators because it contains due diligence and independent risk assessment. The enhanced version is obviously preferable to the standard version, because it provides specific due diligence, auditing done by subject matter experts, and leads to an independent risk assessment. The risk assessment reveals strengths and weaknesses further provides actionable recommendations. The standard version is less expensive to draft than the latter, but can be used as a baseline to ensure that your company is taking some affirmative actions to contain the spread of the coronavirus.

The Guidance is unequivocal in its directives: 

The adverse economic effects of a pandemic could be significant, both nationally and internationally. Due to their crucial financial and economic role, financial institutions should have plans in place that describe how they will manage through a pandemic event. Sound planning should minimize the disruptions to the local and national economy and should help the institution maintain the trust and confidence of its customers. [Emphasis in original.]

According to the Guidance, “pandemic planning presents unique challenges to financial institution management. Unlike natural disasters, technical disasters, malicious acts, or terrorist events, the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration.”

The following constitute the actions that management should be undertaking, per the Guidance:

1. A preventive program to reduce the likelihood that an institution’s operations will be significantly affected by a pandemic event, including the monitoring of potential outbreaks, educating employees, communicating and coordinating with critical service providers and suppliers, in addition to providing appropriate hygiene training and tools to employees.

2. 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, such as first cases of humans contracting the disease overseas, first cases within the United States, and first cases within the organization itself. The strategy will also need to outline plans that state how to recover from a pandemic wave and proper preparations for any following wave(s).

3. 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. Such procedures could include social distancing to minimize staff contact, telecommuting, redirecting customers from branch to electronic banking services, or conducting operations from alternative sites. The framework should consider the impact of customer reactions and the potential demand for, and increased reliance on, online banking, telephone banking, ATMs, and call support services. In addition, consideration should be given to possible actions by public health and other government authorities that may affect critical business functions of a financial institution.

4. A testing program to ensure that the institution’s pandemic planning practices and capabilities are effective and will allow critical operations to continue.

5. 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 governmental sources or by the institution’s monitoring program.

The Guidance provides helpful and important links to information resources, as follows:

1. The National Strategy for Pandemic Influenza (National Strategy) and the Implementation Plan for the National Strategy for Pandemic Influenza  (National Implementation Plan) issued by the federal government provide a complete guide to pandemic planning. 

The documents can be found at https://www.cdc.gov/flu/pandemic-resources/index.htm.