Credit unions have been expected by NCUA to plan for business continuity since their 2008 joint guidance with the FFIEC. At the time, they stated, “the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration.” It also notes that “perhaps the most significant challenge likely from a severe pandemic event will be staffing shortages due to absenteeism.”
FFIEC pandemic planning information continues to encourage financial institutions to take action to minimize impact to consumers.
CU PolicyPro model policy #2195 is Pandemic Influenza Preparedness & Response and can serve as a basis for implementing or updating your credit union’s plan.
The Business Continuity page in InfoSight contains important information and sample policies and is being updated regularly.
Economic Stimulus payments began arriving in mid-April and continued for several weeks, both via ACH and paper check. Refer to the resources below for common questions and challenges related to them.
The Phased Reopening of Montana started on April 26 for Phase 1 and June 1 for Phase 2. It requires some safety measures for employee and member safety. We have policy and questionnaire templates available here and Phase II guidance as well.
These guidelines can be used to determine how to handle employees that may have been exposed to COVID, or who may have tested positive and want to return to the workplace.
The Governor’s Nov. 17 updated directive requires face masks for anyone age 5 and older in any business located in Montana (removing the restriction to only counties with at least 4 active COVID cases.) It also requires signage on public entrances.
Other helpful resources include:
- Sept 11 Update from US Dept of Labor on FFCRA Leave
- Montana Dept. of Labor COVID Resources for Employers
- Best Practices: Bringing Employees Back to the Workplace Webinar (see the Video Series section by AE on this page)
- CDC Toolkit for Businesses with FAQ, guidance, social media information, posters, and more
- Coronavirus Resources for Employers in InfoSight
- CUNA CompBlog on getting paid leave reimbursement
- The WellVia program for employees and dependents of the MCU Group Benefit Trust allows remote check in with a doctor.
- The U.S. Dept. of Labor guidance on FFCRA includes fact sheets, Q&A, and posters for employers
- Employers need to provide the FFCRA poster with paid leave rights (by April 1)
- CUNA Mutual Group FAQ on retirement plans related to coronavirus
- NCUA Alert on remote work cybersecurity considerations
The CARES Act authorized SBA-certified lenders to offer loans that provide small businesses with funds to continue to pay employees and expenses like interest on mortgages, rent, and utilities.
NCUA and other regulators issued a statement March 9 encouraging financial institutions to work with borrowers and affected communities. They stated “Prudent efforts that are consistent with safe and sound lending practices should not be subject to examiner criticism.” Other directives, highlighted below, have since been issued to clarify details.
NCUA has a page with all COVID-19 related materials, including —
The Montana Division of Banking also issued–
- March 20 Statement for state-chartered CUs
- March 31 letter notifying credit unions of Directive prohibiting residential foreclosures and encouraging flexibility.
- April 2 Emergency Rule to allow virtual annual meetings
- Model Bylaws revision to incorporate virtual meetings option
- Division FAQ on foreclosure directive released
FinCEN issued guidance (4/3) regarding BSA obligations during COVID.
*Guidance from all federal regulators and state agencies was issued on 6/23 about how COVID relief activities will be viewed in exams and areas they will not criticize.
Montana moved to Phase 2 June 1. The Phased Reopening of Montana Directive has important information for credit unions to consider. It requires social distancing, disinfection, and employee screening. Check with your county health department to see if they have additional guidance.
Below are resources to consider as your credit union moves toward opening lobbies and returning to full service in branches.
Along with all the news of COVID-19 and stimulus payments that are now hitting accounts comes news of scams and fraudulent situations. Below are some resources and recent alerts:
