Dust Off Your Flu Pandemic Policy Before You Are Asked About It

Written By: Jay L. Hack

group of people wearing masks and accepting folder from another person

With everyone talking about Coronavirus, don’t forget the Interagency Statement on Pandemic Planning. https://www.fdic.gov/news/news/financial/2008/fil08006a.pdf. When it was issued, banks were supposed to develop a written policy to deal with H1N1 flu, SARs, MERs, and other potential pandemics. You should already have such a policy. Expect to be asked about it at your next regulatory examination, so be prepared. Coronavirus presents at least two different risks – first, that your employees will be affected by the virus and, second, that you will be criticized by your regulators for being unprepared.

Today's Takeaway? Review your current Pandemic Policy. Revise it based upon changes to your organization since the policy was last updated. Make sure that your employees have been trained on the policy and refresh that training if appropriate. Involve your board at its next meeting and make sure your minutes reflect the board’s discussion. We recommend that you circulate to all employees the CDC Interim Guidance for businesses.


If you do not already have a Pandemic Policy, we would be happy to help you develop one.

about the authors

Jay L. Hack


Mr. Hack’s primary practice focus is providing a full range of legal services to banks and other financial institutions.

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