May 21, 2020 | Posted by Michael Berman
Clock Image
3 Minute Read

Now that we’re months into the COVID-19 pandemic, financial institutions can finally begin assessing their pandemic performance.

Pandemic response will be a hot-button issue for examiners going forward as they investigate whether your FI followed FFIEC pandemic guidance and how effective your pandemic response was.

Here are five tips to help you prepare:

1. Break down your response function-by-function

A good pandemic plan (or business continuity plan if that’s what you were working off) should identify critical functions and what will be done to ensure resiliency. 

Go through each function to see how well it has performed during the pandemic. (If you haven’t already identified critical functions, do this now and then consider their performance.) Did everything go as planned? Were there surprises? 

2. Assess the effectiveness of each control

Your pandemic plan should have controls to ensure critical functions remain online. Go through each control and rate each one’s effectiveness using a quantifiable scale. This will make it easy to understand the strengths and weaknesses of your pandemic response.

3. Look for gaps and strengths in your plan

There will be some areas where your FI nailed its pandemic response and other areas that were weaker. Review your assessments to find these areas.

Recognize where things didn’t go as smoothly as they should have as well as what went right.

Don’t forget to praise your team for the areas of success! It’s easy to dwell on what went wrong, but people also need to hear what they did well. Everyone is dealing with an unprecedented situation and needs encouragement. Recognize where things did go as smoothly as they should have. Don’t just highlight what went wrong. 

4. Remember that hindsight is 20/20

When assessing your FI’s performance, don’t judge yourself on the information we have today—judge it on the information that was available at the time. It’s easy to look back and say “What was I thinking?”

But just like that prom picture of you in the powder blue tuxedo and the ruffled shirt or the senior portrait with the Aqua Net hair, you need to recognize your response as the product of a very specific time and place. You were following the trends and best practices at the time using the information you had. Unless you missed a big piece of information you honestly should have had, give yourself a break. This pandemic has introduced a lot of unknowns.

5. Adjust your plan going forward

Now that you’ve identified any weaknesses, adjust your pandemic plan to fill in the gaps, and strengthen your future performance. While we all hope we never again face a pandemic situation once this one ends, hope is not a plan. 

For more insights into assessing your FI’s pandemic performance, download our Post-Pandemic Incident Assessment. This tool breaks down the crisis management controls and functions your FI should assess and highlights key questions you need to ask.

 

Michael Berman

Michael Berman

Michael Berman is the founder and CEO of Ncontracts, a leading provider of risk management solutions. His extensive background in legal and regulatory matters has afforded him unique insights into solving operational risk management challenges and drives Ncontracts’ mission to efficiently and effectively manage operational risk.