Are you prepared for the next pandemic?

January 29, 2020 at 9:32 am Leave a comment

I certainly don’t want anyone to overreact, but as I was getting ready to go this morning, I listened to the news that the coronavirus is continuing to spread. In addition, with an incubation period of 14 days, an epidemiologist interviewed on Bloomberg predicted that as many as 100,000 people could ultimately be infected.

It’s time to start dusting off those continuity plans addressing what steps your credit union would take in the event of a wide-spread virus. Here are a couple of good places to start:

In 2006, there was wide-spread fear of an influenza pandemic. The financial regulators, including the NCUA, responded with this inter-agency statement on Pandemic Planning.

In 2014, we had the Ebola Outbreak. One of the most helpful analyses of the legal issues confronted at the time by employers was this blog post from Bond Schoeneck & King, which addressed issues such as the extent to which employers could inquire about employees’ travel plans.

There are also regulations you are already subject to. For example, Federal law requires employers to provide employees a place of employment free of “recognized hazards that are causing or are likely to cause death or serious physical harm” to employees (29 USCA section 654). Consistent with this obligation OSHA issued this guidance during the flu epidemic.

Now I want to stress that all of these outbreaks are unique and raise different issues. Furthermore, I’m not aware of any formal regulatory requirements that have been imposed on financial institutions as a result of the coronavirus. But as I like to say, I am paid to be paranoid, and now is a good time to start answering the questions that you could be asked if this virus spreads.

Another day, another data breach

In the immortal words of the second greatest American entertainer of the 20th Century, Ray Charles, “Here we go again.” KrebsonSecurity is reporting that convenience store chain Wawa has been victimized by a nine month data snatching security breach. This is based on news that the bad guys are already offering to sell personally identifiable information on the dark web. Rather than go through the usual litany of complaints I think I’m just going to let Ray Charles finish out the blog with one of my favorite songs:

I’ve been there before
And I’ll try it again
But any fool knows
That there’s no way to win
Here we go again
She’ll break my heart again
I’ll play the part again
One more time

 

 

 

 

 

 

Entry filed under: Compliance, General, HR. 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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