NCUA Provides Guidance on Pandemic Planning in Wake of Coronavirus

Credit unions should revisit their business continuity plans to ensure preparedness.



As of Feb. 4, the CDC reports 28 countries have confirmed 2019-nCOV (coronavirus) cases. The worldwide spread of the coronavirus has raised pandemic fears, which means credit unions should take the opportunity to review their pandemic planning as part of their business continuity plan.

The coronavirus was declared as a public health emergency of international concern by both the CDC and World Health Organization. Reports indicate that the virus has killed more than 900 people and infected over 40,000. To put it in perspective, the 2019-2020 flu has infected over 15 million people in the United States, hospitalized over 140,000 people worldwide, and killed over 8,200.

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.

Credit union preparedness plans should include:  

  • A preventative program to reduce the likelihood that 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 NWCUA’s Compliance Resources. CU PolicyPro Model Policy 2195: Pandemic Influenza Preparedness & Response provides a general policy that credit unions 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 credit unions can utilize for their plans.

Other considerations when it comes to any sickness outbreak include:

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

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)

Legal Briefs

Federal Trade Commission (FTC)

Fake Check Scams
The FTC released an update showing that fake check scams led to reported individual median losses of nearly $2,000. According to the new data analysis, consumers in their 20s are more than twice as likely as people 30 and older to report losing money to these scams.

Credit Union National Association (CUNA)

Fourth Quarter 2019 Updates to MLA Credit Card Fee Comparison Spreadsheet
The recently updated fourth quarter 2019 fee comparison spreadsheet has been uploaded in CUNA’s Compliance Community in the CUNA Compliance Tool folder and is also available under the Resources tab in the MLA topic of CUNA’s E-Guide.

Internal Revenue Service (IRS)

IRS Launches Identity Theft Central
The IRS launched Identify Theft Central, which is designed to improve online access to information on identity theft and data security protection for taxpayers, tax professionals, and businesses.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of Feb. 7. The last update prior to this was Jan. 31.