The Federal Reserve has sent a wake-up call to bank executives who don't have business continuity plans in place for a possibly devastating flu pandemic. "No individual or organization is exempt from the potential adverse effects," warned Roger T. Cole, director of the Fed's division of banking supervision and regulation, in a Dec. 12 letter to all banking organizations under its jurisdiction. In that missive, the Fed provided criteria for adequate pandemic planning that included preventive programs to minimize the impact of an outbreak; documented strategies to deal with progressively worsening conditions; a comprehensive infrastructure of facilities and staff to handle the outbreak; and testing and oversight programs.

The mere thought of customers making a run on banks at the first signs of an outbreak frightens the Fed. But it's not just financial institutions that should be taking the threat seriously, says Regina Phelps, founder and CEO of business continuity consultant Emergency Management and Safety Solutions. At a minimum, she recommends arranging for employees to work remotely, finding alternative suppliers and cross-training employees to fill in for others. The problem, Phelps says, is overcoming the corporate inertia to put plans in place and test them.

The shortage of staff will be the most significant challenge, predicts Cole, but one that can be addressed in advance.. Other considerations, consultants say, include stockpiling gloves, masks and respirators; enforcing strict hygiene requirements; and instituting rules to limit contact among employees.

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Cole and the Fed have reason to be concerned. A recent simulated pandemic exercise involving 2,775 financial institutions indicated that few are confident in their preparation plans to date. Only 11.7% of the finance executives participating in a recent three-week online test say they have "very" effective plans for business continuity in case of a pandemic, with 2.8% acknowledging no plans; 28% conceding to "minimal" efforts and 56.2% claiming to have "moderately" effective programs in place. The online exercise sponsors–the Financial and Banking Information Infrastructure Committee (FBIIC), a presidential committee, and the Financial Services Sector Coordinating Council for Critical Infrastructure Protection and Homeland Security (FSSCC), an industry organization–said full results of the test will be released in January.

The test results are alarming, admits Dr. James Reynolds, managing director in Mercer Human Resources' health and productivity management practice "Not enough companies are thinking about a pandemic," Reynolds concludes. "And most are not going to prepare before a disaster strikes."

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