REGULATORY EXPECTATIONS. Linda B. Charity Director Division of Financial Institutions Office of Financial Regulation

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Debra Armstrong
8 years ago
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1 Linda B. Charity Director Division of Financial Institutions Office of Financial Regulation

2 Y2K, September 11, 2001, and Hurricane Katrina were significant wake-up calls for developing and implementing a viable Business Continuity Plan and Disaster Recovery Planning.

3 Regulatory guidance, in the form of a white paper from the Federal Reserve, Office of the Comptroller of the Currency, and Securities and Exchange Commission, and the Business Continuity Planning Booklet issued by the Federal Financial Institutions Council (FFIEC), has established new baselines for Business Continuity Plans.

Commission, and the Business Continuity Planning Booklet issued by the Federal

4 What is the fundamental difference between a Business Continuity Plan and a Disaster Recovery Plan? Think of the Business Continuity Plan as your institution s document that will facilitate the Disaster Recovery Plan. Your Disaster Recovery Plan deals with the technical, while your Business Continuity Plan focuses on the human element and necessary processes required immediately following an event.

5 Without a well thought out, and prioritized Business Continuity Plan, your Disaster Recovery Plan will be of no use -- after all what good are your systems if you do not have the correct resources in place to implement your high priority processes?

use -- after all what good are your systems if you do not

6 What Makes Up a Good Business Continuity Plan? A good business continuity plan is a work in progress. Because your bank is a dynamic organization with changing processes and resources, the Business Continuity Plan needs to keep pace with changes in infrastructure, strategy, technology, and human resources

Because your bank is a dynamic organization with changing processes and

7 KEY ELEMENTS Enterprise-wide focus Scalability Business Impact Analysis and Risk Assessment Roles and Responsibilities

8 KEY ELEMENTS Data Back-up and Contingency Plans Crisis Management Communication Testing and Updates

9 Third Parties Documentation Staff Awareness and Training

11 FloridaFIRST evolved from a March 2005 meeting between the Treasury Department, the Florida Bankers Association, and a group of Florida bankers.

12 FloridaFIRST currently has two chapters established: South East Florida Region and Tampa Bay Region.

13 FloridaFIRST has developed a phased plan to assist financial institutions with planning for a pandemic.

14 Treasury to Sponsor First Pandemic Flu Response Exercise Focused on Financial Sector Florida Coalition to Host Program The Treasury Department in cooperation with the FloridaFIRST regional financial coalition will sponsor the first U.S. pandemic flu response exercise focused on the financial sector Thursday, June 22 in Miami, Fl. Florida Bankers News Article: FloridaFIRST: protecting our financial sector Protection of the Florida Financial Sector is Paramount.

first U.S. pandemic flu response exercise focused on the financial sector Thursday, June 22 in Miami, Fl.

15 CSBS Pandemic Response Initiative FFIEC Pandemic Working Group Meeting: The committee is working towards finalizing several draft documents to include: 1-Supervisory Tools to Minimize Disruption 2- Interagency Coordination 3- Examiner and Industry Guidance (part of FFIEC BCP Examination Handbook) 4- Outreach Questions to Industry (to be used during pandemic to maintain a database) 5- Outreach Questions The documents will be finalized and maintained in an interagency repository to be accessible by all agencies. The group also discussed working with ABA and BITS to put together an Industry Roundtable early next year.

Outreach Questions to Industry (to be used during pandemic to maintain a database) 5- Outreach Questions The documents will be finalized and maintained in

16 Useful Websites Guidance on Preparing Workplaces for an Influenza Pandemic: FloridaFirst: Center for Disease Control: National Strategy for Pandemic Influenza: Department of Homeland Security: df Florida Department of Emergency Management:

pdf National Strategy for Pandemic Influenza: http://www.whitehouse.gov/homeland/pandemic-influenza.

Testimony of. Edward L. Yingling. On Behalf of the AMERICAN BANKERS ASSOCIATION. Before the. Subcommittee on Oversight and Investigations.

Testimony of. Edward L. Yingling. On Behalf of the AMERICAN BANKERS ASSOCIATION. Before the. Subcommittee on Oversight and Investigations. Testimony of Edward L. Yingling On Behalf of the AMERICAN BANKERS ASSOCIATION Before the Subcommittee on Oversight and Investigations Of the Committee on Financial Services United States House of Representatives