REGULATORY EXPECTATIONS

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REGULATORY EXPECTATIONS
Linda B. Charity Director Division of Financial
Institutions Office of Financial Regulation
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REGULATORY EXPECTATIONS
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.
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REGULATORY EXPECTATIONS
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.
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REGULATORY EXPECTATIONS
What is the fundamental difference between a
Business Continuity Plan and a Disaster Recovery
Plan? Think of the Business Continuity Plan as
your institutions 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.
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REGULATORY EXPECTATIONS

• 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?

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REGULATORY EXPECTATIONS
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

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REGULATORY EXPECTATIONSKEY ELEMENTS

• Enterprise-wide focus
• Scalability
• Business Impact Analysis and Risk Assessment
• Roles and Responsibilities

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REGULATORY EXPECTATIONSKEY ELEMENTS

• Data Back-up and Contingency Plans
• Crisis Management
• Communication
• Testing and Updates

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REGULATORY EXPECTATIONS

• Third Parties
• Documentation
• Staff Awareness and Training

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

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

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FloridaFIRST has developed a phased plan to
assist financial institutions with planning for a
pandemic.
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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.
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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. 
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Useful Websites Guidance on Preparing Workplaces
for an Influenza Pandemic http//www.osha.gov/Pub
lications/influenza_pandemic.html FloridaFirst
www.flafirst.org/ Center for Disease Control
http//www.ffiec.gov/ffiecinfobase/booklets/bcp/bu
s_continuity_plan.pdf National Strategy for
Pandemic Influenza http//www.whitehouse.gov/home
land/pandemic-influenza.html Department of
Homeland Security http//www.pandemicflu.gov/plan
/pdf/CIKRpandemicInfluenzaGuide.pdf Florida
Department of Emergency Management
http//floridadisaster.org/