As Tennessee continues to respond to the COVID-19 pandemic, the Tennessee Department of Financial Institutions is issuing this interim guidance to all non-depository financial institutions and individuals licensed or registered with the Compliance Division.
In general, please be reminded that business continuity plans (BCPs) should address the threat of pandemic outbreak and the potential impact on the delivery of financial services. Unlike business continuity planning, pandemic planning is much more difficult to determine because of the anticipated difference in scale and duration. The most significant challenge from a severe pandemic event will likely be staffing shortages due to absenteeism. Additionally, open communication with third parties, especially critical service providers, is an important aspect of pandemic planning. Management should have action plans for triggering events, communicate to employees, mitigate risks, and ensure sufficient internal and external capacity is available where needed. Preparation is key in a pandemic event so the need for periodically updating and exercising your plan is crucial for success.