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Pandemic Planning for State Banks, Credit Unions, and Public Trust Companies

Tuesday, March 17, 2020 | 07:45pm

To: Chief Executive Officers of State Banks, Credit Unions, and Public Trust Companies

From: Commissioner Greg Gonzales Date: March 16, 2020

Subject: Pandemic Planning

As Tennessee continues to respond to COVID-19, the Department is providing general guidance and
highlighting resources in an effort to help financial institutions minimize potential disruptions
of services to consumers, businesses, and communities.

To meet Governor Lee’s goals to maintain Department operations while taking measures to stem the
spread of the disease, the Department is suspending onsite examinations and examiners will be
engaged in exams or other supervisory activity offsite until the end of March when we will reassess
the situation.

The FFIEC has updated interagency guidance related to Pandemic Planning to remind institutions that
business continuity plans (BCPs) should address the threat of pandemic outbreak and the potential
impact on the delivery of critical financial services. Unlike business continuity planning,
Pandemic Planning is much more difficult to determine because of the anticipated difference in
scale and duration. The most significant challenge from a severe pandemic event will likely be
staffing shortages due to absenteeism. Additionally, open communication with third parties,
especially critical service providers,  is an important aspect of Pandemic Planning. Management
must have action plans for triggering events, communicate to employees, mitigate risks, and ensure
sufficient internal and external capacity is available where needed. Preparation is key in a
pandemic event so the need for periodically updating and exercising your plan is crucial for
success. See the related links below for the complete guidance.

Additionally, the Department’s Bulletin FI-18-01, “Emergency Preparedness Guide,” is another
resource for state-chartered institutions. It contains answers to frequently asked questions
regarding disaster/pandemic events such as temporary closings/relocations, and contact information
for Department personnel. It has been attached for your convenience.

The Department is working with Governor Lee and other state agencies to best address this ongoing
situation. Externally, the Department continues to work with our partners at the Conference of
State Bank Supervisors, National Association of State Credit Union Supervisors, Tennessee Bankers
Association, Federal Deposit Insurance Corporation, the Federal Reserve System, National Credit
Union Administration, and Tennessee Credit Union League to implement appropriate actions to ensure
the safety of the Tennessee financial institution community and all stakeholders.

If you have any questions or concerns, please contact the Department and we would be happy to
schedule a call with you.

Related Links

FFIEC Pandemic Guidance
https://www.ffiec.gov/press/PDF/FFIEC%20Statement%20on%20Pandemic%20Planning.pdf 

CISA COVID-19
https://www.cisa.gov/sites/default/files/publications/20_0306_cisa_insights_risk_management_for_novel_coronavirus_0.pdf

CDC COVID-19
https://www.cdc.gov/coronavirus/2019-ncov/index.html

Tennessee Department of Health
https://www.tn.gov/health/cedep/ncov.html