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ARTICLE · 17 APRIL 2020

US Banking Regulators Issue Guidance On Pandemic Planning

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On March 6, 2020, the US federal banking regulators issued updated guidance on the actions that financial institutions should take to minimize the potential adverse effects of a pandemic

United StatesFinance and Banking
Thomas Delaney
Thomas Delaney
Matthew Bisanz
Matthew Bisanz
Charity J. Fort
Charity J. Fort
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On March 6, 2020, the US federal banking regulators issued updated guidance on the actions that financial institutions should take to minimize the potential adverse effects of a pandemic ("2020 Guidance").1 In addition to the 2020 Guidance, the New York Department of Financial Services ("NYDFS") issued several letters outlining expectations for pandemic planning and risk management.2

As discussed below, the 2020 Guidance does not break new ground, but the NY Letters lay out detailed expectations that could be the focus of supervisory scrutiny as institutions eventually recover from the COVID-19 crisis.

Background

In December 2007, the US federal banking regulators issued guidance on how financial institutions should prepare for a pandemic.3 It stated that each financial institution should establish a plan for how it will manage a pandemic event. Plan were to include:

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