Pub. 1 2020 Issue 3

www.cbak.com 10 In Touch DEALING WITH PANDEMIC DISRUPTION BY BILL ELLIOT, CRCM, DIRECTOR OF COMPLIANCE EDUCATION, AND WILLIAM J. SHOWALTER, CRCM, CRP, SENIOR CONSULTANT, YOUNG & ASSOCIATES, INC., F or years banks have had pandemic policies, and have done some level of testing, but never really thought the day would come when it would represent more than another examiner-required policy. Then came COVID-19, and in a matter of days, our world changed. Managing Bank Policies and Procedures When we teach in live seminars, we always ask, “How many of you believe that your policies are up-to-date?” That always gets some hands, but not 100% of attendees. Then we ask, “How many of you believe that your procedures are up- to-date?” Seldom does anyone raise their hand. These two situations are revealing. Keeping policies current is the easier of the two. But many banks rubber stamp policies that could be much more effective. If it is a Regulation B policy, it usually follows the regulation and indicates that the bank intends to comply. But other policies, notably operations and loan policies, need to do more than restate a regulation — they need to be a document that can be read and used. And, a pandemic policy needs to cover a wide range of subjects and issues. Given the current situation, it might be time to review these types of policies and add significant language as to how you will address situations such as we have now — lobbies closed or restricted, limited staff, staff working from home, and the same job to be completed. At a minimum, these policies should address: • How jobs are done in an off-site world • How electronic solutions are to be used • Safeguards that must be used to protect customer data • What types of paper documents can be used “at home” by staff working off-site • Proper disposal and the safekeeping of any documents that are off-site, and • Other protections, such as how the computers being used at home are protected from intrusion With a little brainstorming, we are sure that you can add to this list. Procedures are more difficult to maintain. A consultant from our company was recently in a bank and was examining procedures. Most of the procedures could be summed up as “Bill takes care of that.” As long as Bill is there, things probably work well. But if Bill is out sick, on vacation or no longer there, how does someone accomplish the task? Procedures are always changing. It is far too easy to tell the three people that CBA Associate Member