NCUA Provides Guidance on Pandemic Planning in Wake of Coronavirus


The worldwide spread of the coronavirus has raised pandemic fears, which credit unions should take as a good time to review their pandemic planning as part of their business continuity plan.

Which leads us back to steps credit unions should be taking to ensure their pandemic preparedness planning can be activated and all them to respond in an effective manner to the incident.  The NCUA has issued guidance on several occasions related to pandemic preparedness and planning.  Letters to Credit Unions 10-CU-10, 09-CU-13; 08-CU-01; and 01-CU-21.

The NCUA highlights that the credit union’s 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.

NWCUA member credit unions may also wish to leverage the NWCUA compliance resources.  CU PolicyPro Model Policy 2195: Pandemic Influenza Preparedness & Response provides a general policy that the credit union can tailor to meet their needs.  The policy covers:

  • Role of the Board
  • Role of the Management Team
  • Planning for impact to credit union operations
  • Planning for impact to employees and members
  • Allocation of resources to protect employees and members during an outbreak
  • Educating employees

Additionally, the Business Continuity topic within the Security channel of InfoSight provides links to various pandemic resources that the credit union can utilize for their plans.

Other considerations when it comes to any sickness outbreak.

  • Communicate and educate employees.
  • Emphasize good workplace hygiene and social distance from those with obvious symptoms.
  • Reinforce sick leave policies, and even option to work remotely if applicable.

Questions? Contact the Compliance Hotline: 1.800.546.4465,

Question of the Week

Q. How do I verify the identity of a non-U.S. person or an undocumented individual who has no driver’s license or passport?

A. According to theBank Security Act, the Customer Identification Program allows verification of identity by eitherdocumentary or non-documentary methods. You are required to get an identification number, but the number does notnecessarily have to be a taxpayer identification number (TIN) if the individual is a non-U.S. person. The identification number canbe an alien identification number or other government identification number from the individual’s country of residence.Additionally, if you can confirm that that the individual has applied for a TIN and that you can get the TIN within a reasonableperiod of time after the account is opened, you can open the account with an identification number.

Related Links

31 CFR 1020.220 (a)(2)(i)-(iii)

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Posted in Compliance News.