All of the federal banking agencies, the CFPB, the NCUA, and the Conference of State Bank Supervisors have reissued 2007 guidance on business-continuity planning (BCP) and operational-risk management related to pandemics. Little changed from the 2007 guidance, the new standards retain corporate-governance expectations for boards and senior management, perhaps requiring attention in the near term as the coronavirus pandemic continues. Although the agencies are now less likely than in 2007 to issue express enforcement orders based on guidance, existing supervisory power gives them ample authority with which to do so when or if desired. This is most likely in instances in which COVID-19 challenges lead to significant operational disruptions, customer loss, or systemic risk. However, the new guidance also provides a checklist for financial institutions of useful procedures and information sources from which to ensure readiness as challenges continue.
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