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Interagency Statement on Pandemic Planning

The FFIEC agencies1 are jointly issuing guidance to remind financial institutions that
business continuity plans should address the threat of a pandemic influenza outbreak and
its potential impact on the delivery of critical financial services. This guidance
supplements both the “Interagency Advisory on Influenza Pandemic Preparedness”
issued on March 15, 2006 by the Board of Governors of the Federal Reserve System, the
Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency,
and the Office of Thrift Supervision, as well as the “Letter to Credit Union 06-CU-06 Influenza Pandemic Preparedness” issued by the National Credit Union Administration in
March 2006.
This 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. 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.

Pandemics are defined as epidemics or outbreaks in humans of infectious diseases that
have the ability to spread rapidly over large areas, possibly worldwide. Several
pandemics have occurred throughout history and experts predict that we will experience
at least one pandemic outbreak in this century.
The current threat originates from an outbreak of avian flu in Asia. It is unknown if an
avian virus will result in a human pandemic. The widespread nature of this virus in birds
and the possibility that it may mutate over time raise concerns that it will become
transmissible among humans, with potentially devastating consequences. The United
States Government has issued a National Strategy that discusses the threat and potential
impact of a pandemic influenza event. The Implementation Plan for the National


The FFIEC is composed of six voting members: Board of Governors of the Federal Reserve System, Federal
Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the
Currency, Office of Thrift Supervision and the State Liaison Committee.

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Strategy identifies roles and responsibilities for the federal government, the private
sector, and others.
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



There are distinct differences between pandemic planning and traditional business
continuity planning. When developing business continuity plans, financial institution
management typically considers the effect of various natural or man-made disasters that
may differ in their severity. These disasters may or may not be predictable, but they are
usually short in duration or limited in scope.2 In most cases, malicious activity, technical
disruptions, and natural/man-made disasters typically will only affect a specific
geographic area, facility, or system. These threats can usually be mitigated by focusing
on resiliency and recovery considerations.
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 nature of the global economy virtually ensures that the effects
of a pandemic event will be widespread and threaten not just a limited geographical
region or area, but potentially every continent. In addition, while traditional disasters and
disruptions normally have limited time durations, pandemics generally occur in multiple
waves, each lasting two to three months. Consequently, no individual or organization is
safe from the adverse effects that might result from a pandemic event. Experts predict
that perhaps the most significant challenge likely from a severe pandemic event will be
staffing shortages due to absenteeism. These differences and challenges highlight the
need for all financial institutions, no matter their size, to plan for a pandemic event when
developing their BCP.
Pandemic plans should be sufficiently flexible to effectively address a wide range of
possible effects that could result from a pandemic. Pandemic plans need to reflect the
institution’s size, complexity, and business activities. The potential impact of a pandemic
on the delivery of a financial institution’s critical financial services should be
incorporated into the ongoing business impact analysis and risk assessment processes.


As evidenced by Hurricane Katrina, while the duration of a specific natural disaster may be relatively brief, the
social and economic recovery from such events can be prolonged.

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The institution’s BCP should then be revised, if needed, to reflect the conclusions of its
business impact analysis and risk assessment.
To address the unique challenges posed by a pandemic, the financial institution’s BCP
should provide for:
1. A preventive program to reduce the likelihood that an institution’s operations
will be significantly affected by a pandemic event, including: 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.3 The strategy will also need to outline plans that state how
to recover from a pandemic wave and proper preparations for any following
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 numbers4 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


The World Health Organization (WHO) tracks the status of virus transmission using a six phase scale; the U.S.
Government uses a six stage scale that has a geographic focus. Financial institutions should be familiar with and
monitor both sources.


A planning assumption from The Implementation Plan for the National Strategy for Pandemic Influenza is that
rates of absenteeism will depend on the severity of the pandemic. In a severe pandemic, absenteeism attributable
to illness, the need to care for ill family members, and fear of infection may reach 40 percent during the peak
weeks of a community outbreak, with lower rates of absenteeism during the weeks before and after the peak.
Certain public health measures (closing schools, quarantining household contacts of infected individuals, “snow
days”) are likely to increase rates of absenteeism.

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information provided by governmental sources5 or by the institution’s
monitoring program.
The traditional BCP methodologies detailed in the FFIEC’s Business Continuity Planning
booklet6 provide a sound framework for institutions developing and/or updating their
pandemic plan, as well as a means to integrate these five key activities into the final
pandemic plan.
The U.S. Government and industry associations have issued extensive and
comprehensive guidance to assist institutions of all types in developing plans for
pandemic events. Institutions should review the following:

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:


The Financial Services Sector Coordinating Committee issued a Statement on
Preparations for Avian Flu, which provides industry-developed guidance for
financial institutions preparing for the potential of a serious influenza epidemic.
The document can be found at:


The Department of Homeland Security (DHS) published The Pandemic Influenza
Preparedness, Response, and Recovery Guide for Critical Infrastructure and Key
Resources. This document is one of the tools DHS developed to enhance
pandemic planning. It provides a source listing of primary government and
pandemic influenza-specific background material, references, and contacts.
Institutions may find the Continuity of Operations – Essential (COP-E) planning
process especially useful. The document can be found at:


The Department of Health and Human Services Center for Disease Control
published Interim Pre-pandemic Planning Guidance: Community Strategy for
Pandemic Influenza Mitigation in the United States – Early, Targeted, Layered
Use of Nonpharmaceutical Interventions. This document provides information
about community actions that may be taken to limit the impact from pandemic
influenza when vaccine and antiviral medications are in short supply or
unavailable. Financial institutions may be asked to plan for the use of the


See References at the end of this Appendix for specific U.S. Government and industry association guides
covering pandemic planning.

This guidance will be included in the upcoming revision to the FFIEC’s Business Continuity Planning booklet.
The booklet can be accessed at:

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identified interventions to help limit the spread of a pandemic, prevent disease
and death, lessen the impact on the economy, and keep society functioning. The
document can be found at:

The Department of Health and Human Services (DHHS) has published a series of
checklists that are intended to aid preparation for a pandemic in a coordinated and
consistent manner across all segments of society. Included are checklists for state
and local governments, for U.S. businesses with overseas operations, for the
Workplace, for Individuals and Families, for Schools, for Health Care and for
Community Organizations. They can also be found at:

Traditional business continuity planning and pandemic planning require management to
follow a cyclical process of planning, preparing, responding, and recovering. However,
pandemic planning requires additional actions to identify and prioritize essential
functions, employees, and resources within the institution and across other business
sectors. The issues discussed below highlight the specific challenges faced by
management and the mitigating controls that should be considered when developing a
pandemic plan.
As with other BCP activities, pandemic planning should not be viewed as solely an
Information Technology (IT) issue, but rather as a significant risk to the entire business.
As such, an institution’s 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.
An institution’s board of directors is responsible for overseeing the development of the
pandemic plan. The board or a committee thereof should also approve the institution’s
written plan and ensure that senior management is investing sufficient resources into
planning, monitoring, and testing the final plan.
Senior management is responsible for developing the pandemic plan and translating the
plan into specific policies, processes, and procedures. Senior management is also
responsible for communicating the plan throughout the institution to ensure consistent
understanding of the key elements of the plan and to ensure that employees understand
their role and responsibilities in responding to a pandemic event. Finally, senior
management is responsible for ensuring that the plan is regularly tested and remains
relevant to the scope and complexity of the institution’s operations.
The potential effects of a pandemic should be a part of the financial institution’s overall
BCP business impact analysis (BIA). The BIA should:
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Assess and prioritize essential business functions and processes that may be
affected by a pandemic;


Identify the potential impact of a pandemic on the institution's essential business
functions7 and processes, and supporting resources;


Identify the potential impact of a pandemic on customers: those that could be
most affected and those that could have the greatest impact on the (local)


Identify the legal and regulatory requirements for the institution’s business
functions and processes;


Estimate the maximum downtime associated with the institution’s business
functions and processes that may occur during a pandemic;


Assess cross training conducted for key business positions and processes; and


Evaluate the plans of critical service providers for operating during a pandemic.
Financial institutions should evaluate the plans and monitor the servicers to
ensure critical services are available. Financial institutions may wish to have
back-up arrangements to mitigate any risk. Special attention should be directed at
the institution’s ability to access leased premises and whether sufficient internet
access capacity is available if telecommuting is a key risk mitigation strategy.

Incorporating the impact of pandemic risk into the institution’s BCP involves additional
complexity since typical disaster or emergency response mechanisms and methods may
not be feasible. For example, moving employees to an alternate facility that is typically
used during a natural disaster or other emergency, may not be an appropriate or feasible
way to continue operations in a pandemic. There may be a shortage of available staff to
relocate and it is possible that the alternate site might be affected by the pandemic. DHS
provides a list of twelve planning assumptions that institutions should consider when
developing the impact analysis.8
The pandemic issues considered in the impact analysis also should involve forecasting
employee absenteeism and considering family care issues that may affect business
operations.9 DHS believes rates of absenteeism will depend on the severity of the
pandemic. In a severe pandemic, absenteeism attributable to illness, the need to care for
ill family members and fear of infection may reach 40 percent during the peak weeks of a
community outbreak, with lower rates of absenteeism during the weeks before and after
the peak. Certain public health measures (e.g. closing schools, quarantining household


The Department of Homeland Security (DHS) Continuity of Operations – Essential (COP-E) planning process
may be useful here. It is contained in the Pandemic Influenza Preparedness, Response, and Recovery Guide and
is available at:


See The National Implementation Plan at



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contacts of infected individuals, or altering or ceasing public transportation schedules) are
likely to increase the rate of absenteeism.
A key part of an institution’s BIA that addresses pandemics is to examine external
factors. For example, assessing the impact of critical interdependencies will involve
making planning assumptions regarding the availability of external services and
prioritizing the effect of possible disruptions. In addition, potential travel restrictions
imposed by health and emergency management officials may limit access to those
services, even if they are still operating.
As noted in the main body of this booklet, the institution’s risk assessment process is
critical and has a significant bearing on whether BCP efforts will be successful.
Important risk assessment and risk management steps that are important for pandemic
planning include:

Prioritizing the severity of potential business disruptions resulting from a
pandemic, based on the institution’s estimate of impact and probability of
occurrence on operations;


Performing a “gap analysis” that compares existing business processes and
procedures with what is needed to mitigate the severity of potential business
disruptions resulting from a pandemic;


Developing a written pandemic plan to follow during a possible pandemic event;


Reviewing and approving the pandemic plan by the board or a committee thereof
and senior management at least annually; and


Communicating and disseminating the plan and the current status of pandemic
phases to employees.

Specific risk assessment and risk management actions arising from a pandemic include
the following:
Coordination with Outside Parties
Open communication and coordination with outside groups, including critical service
providers, is an important aspect of pandemic planning. Financial institutions should
coordinate information sharing efforts through participation in business and
community working groups and develop coalitions with outside parties to provide
support and maintenance for vital services during a pandemic. Efforts could include
consideration of cooperative arrangements with other financial institutions within the
institution’s geographical trade area. In addition, management should coordinate its
pandemic planning efforts with local public health and emergency management
teams, identify authorities that can take specific actions (e.g., who has the ability to
close a building or alter transportation), and plan to alert local and state agencies
regarding significant employee absenteeism that may be caused by a sudden
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pandemic outbreak. Communication with customers and the media is also critical to
ensure that accurate information is disseminated about business operations.
Critical interdependency challenges require management to ensure an adequate
reserve of essential supplies and to proactively manage maintenance of equipment to
ensure sustainability during service disruptions. Management should also monitor its
service providers, identify potential weaknesses in the service and supply chains, and
develop potential alternatives for obtaining critical services and supplies.
Identification of Triggering Events
A triggering event occurs when an environmental change takes place that requires
management to implement its response plans based on the pandemic alert status.
Alerts may be issued by various organizations that have developed surveillance
systems to monitor the progression of viral outbreaks. Depending on the severity of
the alert, management may need to act quickly to implement elements of its pandemic
response plans. Therefore, it is important for management to monitor national and
international pandemic news sources in order to be aware of potential outbreaks.
Management should monitor websites devoted to national health care issues, identify
key points of contact for emergency and health care organizations, and assess
potential implications for the financial institution if a pandemic occurs. Management
also should communicate to employees and key service providers the actions it plans
to take at specific triggering points.
Employee Protection Strategies
Employee protection strategies are crucial to sustain an adequate workforce during a
pandemic. Institutions should promote employee awareness by communicating the
risks of a pandemic outbreak and discussing the steps employees can take to reduce
the likelihood of contracting a pandemic virus. The following risk management
strategies should be considered:

Publicize the Centers for Disease Control and Prevention “Cover Your Cough”
and “Clean Your Hands” programs or other general hygiene programs;


Encourage employees to avoid crowded places and public transportation systems;


Implement “social distancing” techniques to minimize typical face-to-face contact
through the use of teleconference calls, video conferencing, flexible work hours,
telecommuting, encouraging customers to use online or telephone banking
services, ATMs and drive-up windows; and


Review and consider the use of other non-pharmaceutical interventions developed
by the Centers for Disease Control and Prevention (more information is available

Mitigating Controls
Despite the unique challenges posed by a pandemic, there are control processes that
management can implement to mitigate risk and the effects of a pandemic. For
example, to overcome some of the personnel challenges, management should ensure
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that employees are cross-trained and that succession plans have been developed. The
institution may be able to leverage plans already established as part of traditional
business continuity planning.
Remote Access
During a pandemic there may be a high-reliance on employee telecommuting, which
could put a strain on remote access capabilities such as capacity, bandwidth, and
authentication mechanisms. Moreover, employees who typically work onsite may not
have remote access authority or the necessary technology infrastructure to work at
home. Analysis of remote access capabilities, mapping of related technology
infrastructure to employee needs during a pandemic, assessing the infrastructure at
the neighborhood level, and considering internal and external capacity are necessary
to help ensure telecommuting strategies will work during a pandemic.
As information from medical and governmental experts about the causes and effects of a
pandemic continues to evolve, an institution’s pandemic plan must be sufficiently flexible
to incorporate new information and risk mitigation approaches. As a result, risk
monitoring and testing of the pandemic plan is important to the overall planning process.
A key challenge for management is developing a testing program that provides a high
degree of assurance that critical business processes, including supporting infrastructure,
systems, and applications, will function even during a severe pandemic.
A robust program should incorporate testing:

Roles and responsibilities of management, employees, key suppliers, and


Key pandemic planning assumptions;


Increased reliance on online banking, telephone banking, and call center services;


Remote access and telecommuting capabilities.

Test results should be reported to management, with appropriate updates made to the
pandemic plan and testing program.
Testing for a pandemic may require variations to the scope of traditional disaster
recovery and business continuity testing, as potential test scenarios will most likely be
different. Alternatives for pandemic testing can include: well orchestrated “work at
home” days for critical and essential employees to test remote access capabilities and
infrastructure; crisis management team communication exercises; table top exercises that
test various scenarios related to escalated absenteeism rates; additional or modified calltree exercises; and community, regional or industry-wide exercises with members of the
financial services sector to test the financial sector’s ability to respond to a pandemic-like
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In addition to references included above, institutions may find these web sites helpful in
their pandemic planning activities:
The official Federal web site,, contains the complete text of
the National Strategy for Pandemic Influenza and other important, related details.
Department of Health and Human Services (DHHS)
Business Pandemic Influenza Planning Checklist (DHHS)
Avian Flu Website (DOD)
Centers for Disease Control (CDC)
World Health Organization (WHO)
U.S. Department of Veterans Affairs (VA)
Department of Agriculture (USDA)!ut/p/_s.7_0_A/7_0_1OB/.cmd/ad/.ar/sa.retrievec
Department of Labor Occupational Safety and Health Administration (OSHA)
Department of State
U.S. Agency for International Development (USAID)
Security and Prosperity Partnership of North America (The North America Plan for
Avian & Pandemic Influenza)

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