On March 9, Nacha issued an Operations Bulletin reminding financial institutions of the importance of reviewing their business continuity plans to ensure that they are prepared to maintain ACH payment processing capabilities in the event of possible workforce disruptions due to the coronavirus pandemic. The complete Operations Bulletin #2-2020 here.

Further, financial institutions should be aware of the expectations of federal regulators (the FFIEC agencies), which on March 6 issued guidance to remind financial institutions that business continuity plans should address the threat of a pandemic outbreak and its potential impact on the delivery of critical financial services. The FFIEC’s Interagency Statement on Pandemic Planning is available here.