GAO says financial markets not ready for a pandemic

May 2, 2007 (CIDRAP News) – A new report from Congress' Government Accountability Office (GAO) says key organizations that are the backbone of the US financial industry need to do more to prepare for an influenza pandemic and urges federal regulators to set deadlines for them to complete pandemic plans.

Pandemic planning is one component of the GAO report, which evaluates the overall preparedness of the financial markets for a range of events, from natural disasters to terrorist attacks. The report notes that the pandemic threat is different from other disasters because it could affect large numbers of people simultaneously and strike in waves that last for weeks at a time over several months.

The GAO focused its attention on seven critical exchanges, markets, clearing organizations, and payment processors, which it did not name. The agency found that although all were planning for a pandemic, only one had completed a formal plan, according to the report, which carries a March 2007 date but was posted on the agency's Web site this week.

Staff at two organizations told the GAO they had begun cross-training employees to handle critical duties, and staff at one organization had conducted a tabletop exercise. Another organization had a draft pandemic plan, but it didn't address how business functions would be maintained through varying levels of absenteeism, the report says.

Though the financial markets have made good strides since the Sep 11 terrorist attacks to spread their operations to dispersed back-up sites, the GAO warns that the industry shouldn't depend on the more dispersed operating centers to help them through a pandemic. "With global airline travel available, any disease outbreak could occur quickly and be widely spread within a short period of time," the report says.

The GAO says that while federal regulators are discussing their pandemic planning expectations with the financial industry, they haven't told industry groups to include a severe pandemic scenario in their planning or to set dates for completing pandemic plans.

"If organizations fail to produce fully robust plans before an outbreak, which could begin at any time, they may have insufficient time and resources to adequately prepare their staffs and customers for changes in how the organizations will operate during a pandemic," the GAO report says.

A letter from federal regulators—including the Federal Reserve, the Comptroller of the Currency, and the Securities and Exchange Commission (SEC)—that accompanies the GAO report acknowledges the importance of pandemic planning for the financial markets but says the groups they oversee have made progress in their planning for even a severe pandemic. The financial organizations' contingency plans "generally address the four elements recommended" in the GAO report, the regulators say.

"If we find organizations' efforts lagging, we will consider taking additional actions, including those you recommend," the letter states.

Both regulators and the financial markets have become concerned about how strong telecommunications systems will be during a pandemic, because most business continuity plans involve telecommuting, the report says. A modeling study from the National Communication System suggested there was enough bandwidth to handle the traffic, but problems could crop up in individual residential or commercial areas. In November 2006, the Financial Services Sector Coordinating Council for Critical Infrastructure Protection and Homeland Security agreed with telecommunications companies to study the potential impacts of a pandemic on telecommunications capabilities.

The GAO also recommends that regulators consider suspending certain rules during a pandemic. For example, broker-dealers will likely work from home during a pandemic, but current rules say they must be directly supervised. "The trade associations noted that the requirement to register new temporary offices as a new branch office should be suspended, as was done after the September 11 attacks and Hurricane Katrina," the report says.

Several US financial services firms participated in a recent 6-week pandemic exercise in the United Kingdom, the GAO says. SEC officials told the GAO they are working with financial market associations to plan a 4-week exercise in the United States, modeled after the UK drill, beginning in September.

See also:

March 2007 GAO report
http://www.gao.gov/new.items/d07399.pdf

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