Credit unions serving first responders will be a primary point of contact as first responders come off duty and into the credit union.
ARLINGTON, Va.—How effective are credit union plans for addressing pandemics and business continuity?
Experts told CUToday.info the growth of the coronavirus that CUs should be reviewing their pandemic and business continuity plans, which likely have not been visited since the SARS outbreak in 2002.
“I think it's too early to tell what kind of impact the coronavirus may have here in the U.S.,” said NAFCU Vice President of Regulatory Compliance Brandy Bruyere about the potential effects on personal health and credit unions’ business. “We're just trying to make sure credit unions have the resources they need to take a look at this so they can be ahead of this.”
Noting the last time many credit unions have likely visited their pandemic planning was in 2002-2003 during the SARS outbreak, Bruyere said CUs need to make plans to minimize the possibility of any effects from a pandemic.
“Address any negative effects from a pandemic and have a documented plan for continued operations,” said Bruyere. “Make sure critical operations can remain in effect. Pandemic planning does differ from more traditional continuity planning, in part because the impact can be difficult to anticipate. So, pandemic plans need to be flexible, and the plans need to reflect the credit union’s size, complexity and business operations.”
The Biggest Risk
Bruyere noted that while NCUA’s supervisory priorities this year do not include reviewing CU pandemic planning, “the agency does have the right to go beyond their stated priorities. I think it's possible they could look at these plans to make sure credit unions have taken a look themselves.”
The biggest risk to credit unions from a pandemic, said Bruyere, is personnel.
“One of the things regulators flag in all of their guidance on pandemic planning is the risk to staff,” said Bruyere. “In these kinds of situations you might have broad absences. You can even see that with localized outbreaks of the flu. Employee protection strategies are important, which include education on how a disease spreads. Address, for example, minimizing face-to-face contact with others if you believe there is an issue in your area. Maybe replace meetings with conference calls…”
Bruyere noted the Federal Financial Institutions Examination Council (FFIEC) recently updated its business continuity management section of its handbook.
“This covers all the bases and includes, but is not limited to, pandemic planning,” she said.
Carlos Molina, senior consultant, Risk and Compliance Solutions, agreed most U.S. workers are not at significant risk of infection at this time, but the situation is evolving.
“It’s never too early to get ahead by addressing employee concerns, taking measures to keep the workplace sanitary and ensuring your employees feel safe,” said Molina.
In a Risk Alert recently sent to CUs, CUNA Mutual group recommended steps to address a pandemic:
Communicate and educate carefully: “Credit unions who reasonably believe they could serve members or have employees who could potentially travel to and from an infected region should be prepared to provide reassurance and education. A statement from credit union management should be made available that the situation is being monitored, and human resources or risk management departments should be prepared to provide information or access to appropriate agencies like the CDC, Department of State, or local health organizations,” CUNA Mutual Group said.
Emphasize good workplace hygiene: “Remind employees of general good workplace hygiene practices such as covering one's mouth when coughing or sneezing, avoiding contact with sick individuals, and washing hands frequently. Consideration should be given to providing tissues and hand sanitizer throughout credit union locations. Waste bins should be emptied frequently and surfaces properly disinfected,” the company said.
Reinforce sick leave policies: “Encourage employees to review company sick leave and paid time-off policies and encourage employees to stay home if they are feeling ill. Remote work arrangements should be utilized if previously agreed upon. A point of contact should be identified to answer any employee questions related sick leave use, or the accrual process,” the Risk Alert stated.
Decisions to send employees home should be made carefully: “Any decision made to send a visibly ill employee home should be done so within existing policy guidelines. Attention should be paid to state wage and hour laws for non-exempt employees where wages may be due even for the period of time they were sent home. If a policy is currently in place that requires an employee to inform the credit union of any direct threat to the safety of other employees, including illness, it should be noted that the credit union must keep all employees' health information confidential, and should ensure that any policy is in compliance with the Americans with Disabilities Act (ADA),” CUNA Mutual Group said.
Avoid mandatory medical examinations and quarantines: “Unless you have a reasonable belief that an employee poses a ‘direct threat’ to the workplace, the ADA prohibits mandatory medical examinations. Any attempt to isolate or quarantine employees without prior authorization by a public health agency or official can lead to risk liability under the ADA, medical privacy laws, state wage and hour laws, and potential national origin discrimination claims,” the company stated.
CUNA Mutual Group outlined additional resources that are also available:
- CUNA Mutual Group’s Protection Resource Center
- Centers for Disease Control and Prevention
- U.S. Department of State
- Occupational Safety & Health Administration Pandemic Preparedness