Over the past several weeks, our team has been monitoring the current situation regarding the Coronavirus (COVID-19). As cases have spread across the country, the PolicyWorks team has been fielding calls from credit unions like yours, inquiring about issues caused by this unexpected pandemic. We know credit unions rely on us to be there, providing the most current and accurate regulatory guidance.
If you are a client, we want to assure you that we have a comprehensive business continuity plan, and we are well prepared to provide service to you should the situation continue to escalate. As we continue to monitor the environment, we are advising our employees to cancel all unnecessary travel and, hold meetings online as much as possible, as a precautionary measure to protect both our employees and our clients. PolicyWorks will continue to fulfill and meet our obligations to you.
If your credit union belongs to a PolicyWorks partner credit union league, the PolicyWorks Hotline will be operating as normal. Please contact us with any COVID-19 -related compliance questions!
As a result of COVID-19, there has been an increased discussion in the industry around credit union BCPs. These plans provide a strategic approach to help lessen the impact that natural or technical disasters and malicious acts can have on credit union operations. Considering the recent developments with COVID-19, credit unions are reminded to review and update their BCPs accordingly to address the actions they should take to minimize the potential adverse effects of a pandemic.
Click here to read a BCP-focused compliance bulletin released last week by our team. This bulletin contains helpful information from the Federal Financial Institutions Examination Council (FFIEC) regarding credit union pandemic preparedness.
Jeremy Smith, PolicyWorks Director of Client Partnerships, wrote this blog on some BCP best practices, including making specific plans, testing them and continually updating them over time.
In a joint statement issued on March 9, 2020, federal financial institution regulators (including the National Credit Union Administration (NCUA), and state regulators said that financial institutions (including credit unions) are encouraged to meet the financial needs of customers and members affected by the coronavirus.
In the statement, regulators are urging financial institutions, including credit unions, to work constructively with borrowers and other customers/members in affected communities. Prudent efforts that are consistent with safe and sound lending practices should not be subject to examiner criticism.
The statement also notes that the agencies recognize the potential impact of the coronavirus on the customers, members, and operations of many financial institutions and will provide appropriate regulatory assistance to affected institutions subject to their supervision. Moreover, the agencies understand that many financial institutions may face current staffing and other challenges. In cases in which operational challenges persist, regulators will expedite, as appropriate, any request to provide more convenient availability of services in affected communities. The regulators also will work with affected financial institutions in scheduling examinations or inspections to minimize disruption and burden.
The NCUA provided additional guidance on this in their letter to credit unions on March 16, 2020. Click here to read more.
Other Considerations for Credit Unions
Contact PolicyWorks if you have questions regarding any of these items or other impacts COVID-19 may have had on your credit union operations.
Centers for Disease Control
NCUA Letters to Credit Unions
World Health Organization (WHO)
U.S. Department of Labor: Occupational Safety and Health Administration (OSHA)
U.S. Department of State
U.S. Department of Veterans Affairs (VA)
U.S. Equal Employment Opportunity Commission
State and Territorial Health Departments
Credit Union League Partner Resources