Exercising for Safety and Soundness

Yes, for the next year or two your bank examiner may make the mistake of crediting you for exercising your disaster plan when you documented an actual crisis but let’s take a step back and think about this before we consider it a “win”.
Experiencing a crisis or disruption does not meet the standard for exercising your plan and should not be adequate to count as testing your plan for many reasons. Including:

1. Under best practice continuity management guidelines it is clear that establishing and testing an exercise program is not the same as documenting events that threaten or impact the business. These are two separate best practices.
2. FFIEC examination guidelines state “The board and senior management should establish a testing program appropriate for the size, complexity, and risk profile of the organization and its business lines”. Passively experiencing crisis does not demonstrate a testing program has been established and, no matter what the extent of the crisis, will it be appropriate for the size, complexity and risk profile of the organization. In fact, it may be counter productive and make you look unprepared because you didn’t plan a test.
3. Community banks are likely to have experienced 6-12 crises in a year. What makes this one particularly meaningful? Did you document the other ones? What are your standards for documentation?
4. Test objectives were not set or met (no, “survival” does not count) and only one part of your response plan was tested. The “test” was not comprehensive.
5. Since you weren’t planning to experience this problem, exercise controls were not in place when you had it. You can only manage what you measure.
6. Hypothetically, would you consider going to the emergency room because you thought you might be having a heart attack to be an indicator for your ability to deal with stress? Technically the answer is “Yes”. However, that’s certainly no way to live and if this is your common practice then it indicates you don’t really have a good plan for your health. The same is true for your organization. Why have a heart attack to wait to check and see if your blood pressure is too high? It’s easier to use a blood pressure cuff and check your heart rate.

Let’s speak the truth: This is not the attitude of a healthy, mature business and will not, for much longer, meet requirements for safety and soundness.
Now, before you get frustrated, I realize you don’t want to do continuity management this way. You have a LOT on your plate that you’d rather be getting to (call reports anyone?) and you’re just not sure where to get started. So, DCS has set up some fantastic tools to make planning exercising EASY for you! Get excited now and bookmark this for future reference! First, go ahead and log that problem you had on our FREE Crisis Event Log. It’s got a couple of brief questions to help you get down the information you need to learn from and properly document the problem.

Next, use our FREE Strategic Road Mapto get an idea about what a good, well-rounded financial institution can do on to build operational strength. NO, you don’t have to do that big fail-over test right away. We actually recommend against it. Start drilling the little things first. Can you guarantee that you can contact everyone when they’re not at work? Try your call tree out and write down what happens. That’s a great test!
Another quick tip is to see what your IT provider is doing to test regularly. We often find out the IT department regularly tests failover procedures but rarely documents it adequately for oversight or examination requirements. All you have to do is start documenting! It’s easy! You can do that!

We have also started a new product line: DIY Turnkey Continuity. We’re building very strong key kits for your continuity tool case at affordable prices. We’ve started with a data breach kit and will be releasing an exercise kit before the end of the summer. For our BOL friends, we are looking for pilot users to test these at a discounted rate! Private message me if you’re interested. Also let me know what other kits you’re interested in. Pandemic, social media and vendor management are on our list for 2013.
I hope these ideas help out. We realize you are doing everything you can to keep compliant and the business moving in a positive direction. Please let us know what else we can do to make your job easier!

Visit-http://www.dcsplanning.com

DCS Planning Business Continuity Consulting

Consider a complex manufacturing and logistics organisation, based at the North Pole, traditionally very busy around the 25th December. As you might imagine, planning for this event takes all year – no sooner has Santa Claus sat down on Boxing Day then he’’s called to deal with all sorts of unplanned events that require attention.

This year, it started early. Santa was putting the sleigh in the garage when he was accosted by Mrs Claus.
““What are these reports on the radio about you kissing somebody’’s Mommy?”” she demanded.
““W, w, what? Who?”” Santa stammered.

Santa was able to explain that there must have been a case of mistaken identity. Santa’’s image had taken a battering at the hands of an imposter. He was straight onto his Incident Management Team and, following a quick injunction and a public apology, his reputation was restored. He couldn’’t afford for his customers to think he was in anyway naughty.

February brought ice storms to the North Pole.

““Sir, it’’s too cold for the employees to work,”” his Elf and Safety Manager told him, “”I have instructed the elves to down tools.””

Santa sighed and reached for the Yellow Pages, “”Hello, heat engineers? It’s just possible you could save my elves…”.”

Despite the interruption, with a bit of overtime, the Elves were soon back on schedule.
Things carried on uninterrupted until spring saw flocks of birds returning from their winter habitats. Concern rose amongst Santa’’s employees that the wild birds may bring the H5N1 avian flu virus with them, giving rise to concerns about an epidemic. Santa consulted the WHO website for the latest advice.

““There’’s currently little risk for us, the birds are returning from countries where there has been no recorded H5N1 outbreaks, but to be sure, I’’ll employ a couple of special wardens specifically to keep an eye on the well-being of the birds”” he told his elves, hoping that he wouldn’’t have to employ more wardens when the wild reindeer herds returned. He’’d read that the Blue Tongue virus was spreading north and already had problems with one of his sleigh crew having a red nose….

The summer holidays always presented Santa with problems, bored children with too much time on their hands were always on the lookout to cause mischief. This year Santa’’s IT partners informed him one morning that his “Naughty or Nice” database had been hacked! The status of all the children had been changed and there was no way they could sort it out.

Fortunately Santa is pretty tech-savvy. He didn’’t panic and instructed his IT department to delete the data and restore from the back up. As extra insurance, he asked for a full virus check to be undertaken, arranged for the firewall firmware to be updated and instructed all the elves to change their passwords.

There were no further problems to distract Santa. Come the 24th, the Elves loaded up the sleigh and the reindeer team was harnessed. Santa clambered up into the driving seat, picked up the reins with one hand and turned the sleigh’s ignition with the other. There was a short croak and then nothing. He turned the key again, with the same result. Santa realised that when he had been managing his reputation issues last year, he’’d forgotten to turn the sleigh headlights off. The battery had gone flat.

Fortunately, on Mrs Claus’ insistence, the date was the 24th of November and Santa and Elves were running an exercise. Sure, Santa hated having to squeeze into his suit before his annual diet had worked off all the previous year’s mince pies, the Elves got cranky at having to load and unload the sleigh and the reindeer team disliked being taken from their warm stables, but Mrs Claus had seen the benefits of exercising ahead of “the “big off””. The battery was rigged up to the charger and, come the big day, all the good children received the right presents thanks to Santa’’s business continuity arrangements….

Just a bit of fun!  Special thanks to Richard Jones!

Eryn Tribble is a certified Associated Business Continuity Professional (ABCP) who offers experience and expertise in Business Continuity Management (BCM) with a focus on employees as the company’s greatest asset and human management in continuity.  Eryn’s BCM understanding ranges from implementing continuity as a project to infusing resilience into the practice of business. She is a dedicated risk specialist with a specialty in finance and commodity trade and supply.  Having worked within global supply chains and trade houses, Eryn brings a unique perspective on diversity and resilience.
Visit- http://www.dcsplanning.com