Updated Guidance Issued on Business Continuity Expectations

November 15, 2019 at 9:04 am Leave a comment

The FFIEC released an updated booklet for examiners, including those employed by the NCUA, to use when assessing a financial institution’s business continuity preparations. The key takeaway is that examiners expect financial institutions to treat business continuity planning as an ongoing management process that considers the needs of the credit union as a whole, as opposed to only protecting its IT functions.

Too many cooks in the kitchen will always result in an overcooked turkey, and I can’t stand parsing through FFIEC guidance because it inevitably reads like a document in which every regulator has to contribute just to show they did. The result is that the guidance is ultimately too general to be of much practical use beyond highlighting key issues that examiners expect financial institutions to address. I believe this guidance is subject to many of the same defects, but you should nevertheless read it and update your policies and procedures to reflect what I think many of you already know: that business continuity involves getting all stakeholders in the credit union committed to an ongoing process of assessing potential threats and developing contingencies for efficiently and quickly keeping your most important operations going. This is no easy task since your credit union has to guard against everything from a cyber-attack to those increasingly-common 100 year storms.

On the most practical level, I would comply with this guidance by demonstrating that the credit union has prioritized the functions and products that it is in most in need of protecting, and ensuring that your IT recovery plan reflects those priorities.

DFS Investigates Apple Card, but the Money Keeps Flowing In

Last weekend, Linda Lacewell, the Superintendent of New York’s Department of Financial Services, reacted swiftly to reports that the Apple-Goldman credit card may be using underwriting criteria that discriminates on the basis of sex. For example, none other than Steve Wozniak explains that his wife was denied a credit card. Suffice it to say that the issues raised by this situation are more complicated than anyone seems willing to acknowledge or grapple with at this point.

In the meantime, things seem to be going just fine for the Apple-Goldman partnership. CU Today reported this morning that Goldman issued $10 billion worth of credit lines under the card.

On that note, enjoy your weekend.


Entry filed under: Compliance, General, HR, technology. Tags: , , , , , .

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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