Why Documentation is an Essential Priority During the COVID-19 Pandemic

While financial institutions have spent the last nine months focused on pandemic response and ensuring critical services remain available to their customers and members, there are other key areas of consideration to ensure their institutions remain compliant and can thrive in the future, including documentation. Unfortunately, few financial institutions are adequately documenting their efforts and new strategies as they are being implemented. Below are three key reasons why they really should.

1. Regulatory Expectations

Examiners will expect to see how financial institutions have handled the pandemic and that all of the lessons learned are reflected in their business continuity management plans (BCMP).

Some key questions regulators may ask regarding pandemic response include:

• What have you learned from this event?
• What have you done to enhance your pandemic plan based on those lessons learned?
• Prior to this event, had you analyzed your business processes and their interdependencies, and prioritized them by recovery time?
• Have you identified employees with job duties capable of being performed remotely? If so, did they have secure, reliable, remote access?
• If those job duties are highly specialized, or highly critical, did you have alternate personnel identified and pre-trained to step in when needed?

2. Key Lessons Learned

All banks and credit unions must take a different approach to pandemic planning that fits well with their institution’s unique needs. They need to consider all of the challenges they’ve faced throughout the pandemic and apply key lessons learned to enhance their operations, including the importance of cross-training staff, enhancing security measures, succession planning, or improving technology for an employee to work at home. Until the pandemic passes, financial institutions should continue to reference their business continuity plans and document the entire process to create a blueprint for reference if a similar situation arises again in the future.

3. Strategic Planning

According to the FFIEC, an entity’s strategic planning should be developed to address all foreseeable risks, and these risks should cover the potential impact on personnel, processes, technology, facilities, and data. Throughout the pandemic, financial institutions should track what they are doing, how they are doing it, and whether any new procedure should be included in their existing crisis management or response plan.

The key is for institutions’ steering or strategic planning committee to stop periodically and document—or backfill information after the fact (at least a month or a quarter later.) Failing to document this process will result in institutions returning to business as usual after the crisis subsides and potentially making serious mistakes if a pandemic situation occurs in the future.

To learn more about pandemic response and key priorities for financial institutions, download our latest white paper, “Navigating the Coronavirus pandemic: Best Practices for Pandemic Planning and Key Lessons Learned for Community Banks and Credit Union.”