The World Health Organization declared the new coronavirus to be a pandemic on Wednesday, March 11, 2020. Was that the day the earth stood still? Well, no, The Day the Earth Stood Still was a black and white science fiction film released in 1951. The classic film featured Klaatu, a “humanoid” alien visitor sent to earth to deliver an important message that would affect the entire human race. Klaatu, accompanied by a powerful eight-foot tall robot named Gort, came to earth in the spirit of peace and goodwill, yet he was shot and wounded by a nervous soldier. In response, the robot Gort emerged from the flying saucer and quickly disintegrated the Army’s weapons.
Things deteriorated from there, and Klaatu found himself on the run from soldiers. He eventually met a famous scientist and explained to him that the people of other planets were concerned about humanity’s development of rockets and a rudimentary form of atomic power. Klaatu declared that if his message was ignored, “Earth will be eliminated.” The scientist questioned such power, but Klaatu demonstrated it by neutralizing all electricity and making everything on the Earth stand still for 30 minutes.
Fast forward 69 years, and we find ourselves in an actual serious threat in a world that seems to have been temporarily frozen in time. Across the country, almost every educational forum, from daycare to college, has been closed for an “early/extended spring break” and many are trying to convert to online instruction. Churches have cancelled standard services and moved online in order to keep some semblance of normalcy. Many cities have limited or prohibited gatherings in bars and dine-in restaurants, requiring service to be delivered through curb-side pick-up, drive–thru or low-contact food delivery services. Our neighbors (and maybe some of us) have overwhelmed the grocery stores and drug stores, stripping the shelves of all the essentials like milk, eggs, cereal, cheese, peanut butter, chocolate chip cookies, dark chocolates, alcohol sanitizers, disinfectant wipes and toilet paper. Note that preppers already have all of this including a shed full of toilet paper. Fortunately, the chip aisle remains well stocked.
Almost all business meetings, banking schools and conventions through the middle of the year have been cancelled or rescheduled. Professional sports leagues have cancelled or put on hold their seasons. College sports have all been cancelled for the spring. Many employers are having their employees work from home. Vacations and trips have been shelved. In some places, curfews have been implemented and increasingly enforced. This is really serious when spring football in the south may vanish.
Our own favorite banks and credit unions are certainly not immune – many are closing their lobbies to all except one-on-one appointments. Customers are now being served through ATMs, ITMs, drive-thru windows, contact centers, online and mobile banking.
While we may not have a Klaatu-like alien arriving and telling us to act right, we can definitely view this period as a warning – a “call to action” for our financial institutions and our country to be prepared for more unpredictable events. Not since the financial crisis of 2008 has an honest-to-goodness Black Swan event appeared out of nowhere to disrupt our normally predictable world. The new coronavirus that leads to the medical condition known as COVID-19, crossed the ocean and turned our lives upside down, introducing a veritable cornucopia of new risks to the entire financial services industry.
All of us are accustomed to dealing with risks and, over time, we have created a multitude of policies and procedures aimed at identifying, preventing, managing and mitigating those risks. Unfortunately, every business cycle seems to bring a new risk or new twist on an old risk. We have heard, read about or experienced pandemics – the Spanish Flu of 1918, SARS in 2003 (a viral respiratory illness caused by an earlier generation coronavirus) and the Swine flu in 2009 (aka H1N1) – but now we are faced with a new and deadly coronavirus and, like Klaatu’s warning but unlike previous pandemic scares, it has effectively shut down the world and truly made it appear to stand still. Without question, the current environment will challenge and test us, our families and our communities.
By this point, every financial institution should have pulled out and begun implementing their Business Continuity Plans. If not, your favorite examiners (who have moved to off-site exams overnight as a result of their business continuity plans) may well be taking you to task.
You may be wondering, though, “In the middle of a crisis, exactly which plan should we use?” More often than not, contingency plans are based on loss of use of branches, offices and support centers due to natural disasters or fire. However, a simple search of the FFIEC website pulls up over 60 articles just on the word “pandemic”. Hopefully, every contingency plan has a special section addressing responses to pandemic situations. Pandemics are not new, not to national governments, states, counties and cities and not to our financial institutions.
Let’s cut to the chase, though. The “Interagency Statement on Pandemic Planning Guidance for Minimizing a Pandemic’s Potential Adverse Effects” issued by the FDIC in FIL-6-2008 is still prescient to today’s issues with guidance concerning very basic, applicable things like “clean your hands” programs, avoidance of crowded places and public transportation, use of “social distancing” techniques and references to CDC guidance. Sound familiar? In case you were wondering, this guidance was recently updated by federal banking regulators on March 6, 2020 (the FDIC’s FIL-14-2020), and with schools and almost all financial institutions meetings being cancelled, you may find yourself with extra time on your hands to read, study and implement appropriate guidance.
It is important to note that there is no such thing as a “One & Done” Pandemic Risk Checklist. Even the regulatory guidance for developing a pandemic response risk management program is only guidance and not an all-inclusive checklist.
It’s also worth mentioning that a pandemic response by your financial institution isn’t just a teller line and management problem. Regulatory guidance clearly calls for boards to be involved:
“An institution’s board of directors is responsible for overseeing the development of the pandemic plan. The board or a committee thereof should also approve the institution’s written plan and ensure that senior management is investing sufficient resources into planning, monitoring, and testing the final plan.”
Even if the exams are offsite for the near future, during 2020 examinations you should expect your financial regulators to review the effectiveness of your contingency plans, how the pandemic guidance has been followed and what new loss exposures you have faced from the current pandemic. Most likely, the examiners will have converted the guidance into checklists to make it easier to evaluate and track your progress. Charting now how you are meeting the expectations of the regulatory guidance will not only document your efforts but might just help identify where more work is needed. It’s not too late.
When it comes to checklists, your team will need to quickly survey the various risk areas of your company for readiness. A few items to consider are as follows:
- How are operational risks being managed to adjust for remote working situations?
- Are credit risk policies sufficient for the potential decline in credit quality over the coming weeks and months?
- Has an assessment been made of the concentration of restaurant and/or hotel loans? The hospitality industry has been heavily impacted as a result of the “lockdowns”, resulting in dramatically reduced travel, a reduction in hotel occupancy (some at 15% occupancy or lower) and limited restaurant operation. The hotel and restaurant industries will create problems for your loan portfolios.
For a more thorough checklist addressing Cleaning Processes, Work Processes, Operational Processes, Asset Quality and Loan Concentration, Policy Readiness and other specific risk considerations, please download our free Pandemic Risk Readiness Checklist.
In addition to our suggestions, the CDC provides guidance with 20 specific actions for employers including:
- Actively encouraging sick employees to stay home
- Immediately separating sick employees
- Emphasizing staying home when sick
- Respiratory etiquette and hand hygiene by all employees
- Performing routine environmental cleaning (again and again during these times)
- Limiting travel or advising employees who must travel to take certain steps before traveling
There is also a page specifically for “Environmental Cleaning and Disinfectant Recommendations.” We all need to check back to CDC frequently for updates. The CDC provides a source of information in general on infectious disease management and on the underlying coronavirus currently circulating. Visit the CDC’s Resources for Businesses and Employers.
The CDC also has a great resource for our employees, encouraging them to develop a Household Plan of Action.
State and local health departments also play a role and may provide information and local requirements. Be involved with your trade groups or associations for information and networking opportunities.
Finally, we are long past the Cold War. There are no flying saucers. There is no Klaatu or Gort, and we are not facing an ultimatum from outer space. But we are at a crossroads and time is short. It is everyone’s job to help “flatten the curve” and that means sacrificing…..that is giving up something we value (like the freedom to come and go at will) for something of greater value (like limiting social interactions and taking the time to wash hands and disinfect surfaces, etc.). We should always be available to our families to “calmly” talk about what’s going on around us – kids of any age get scared. When you are working from home or in the office (always practicing “social distancing”, of course), talk to your customers and friends by phone, email, text or skype and carefully listen for ways you can help them get through our current national crisis.
Almost exactly 87 years ago on March 12, 1933, in Franklin Delano Roosevelt’s first Fireside Chat he reminded all Americans that “Confidence and courage are the essentials of success in carrying out our plan. You people must have faith; you must not be stampeded by rumors or guesses. Let us unite in banishing fear.” Great advice for our world in 2020.
Our financial institutions are meant to be sources of strength in a crisis and we have work to do to help employees and customers and to aid the economy’s recovery. Be calm, be prepared and be ready for the challenge.
Please stay healthy and choose wisely.
We would welcome any additions to this checklist that you may have identified in your financial institution. Please email any additions or insight you have to Randy Dennis at email@example.com.
J. Robert Kelly, a retired banker with over 40 years experience in auditing, finance, operations and risk management primarily with community and midsized banks, contributed to the research and preparation of this article.