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OCC Bulletin 2020-13 | March 6, 2020

Pandemic Planning: Updated FFIEC Guidance


Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Office of the Comptroller of the Currency (OCC), along with other members of the Federal Financial Institutions Examination Council (FFIEC), today issued updated guidance to remind financial institutions that their business continuity plans should address the threat of a pandemic outbreak and its potential impact on the delivery of critical financial services. The guidance identifies actions that banks1 should take to minimize the potential adverse effects of a pandemic. This bulletin rescinds OCC Bulletin 2007-49, "Pandemic Planning: Interagency Guidance," issued on December 18, 2007.

Note for Community Banks

This guidance applies to all OCC-supervised banks.


The guidance

  • explains the difference between traditional business continuity planning and pandemic planning.
  • reminds banks of the traditional phases of business continuity planning (planning, preparing, responding, and recovering) and states that pandemic planning requires additional actions to identify and prioritize essential functions, employees, and resources.
  • lists websites that offer information on pandemic planning activities.

Further Information

Please contact Patrick Kelly, Director for Critical Infrastructure Policy, at (202) 649-6550.


Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Links

Also refer to the following pandemic planning and preparedness resources:

1 The term "banks" refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.