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DISASTER RECOVERY RISKS. LESSONS LEARNED. DISCLAIMER. The information contained in presentation represents generic industry information and does not express the views of Hancock Bank Holding Company (HBHC) or any of its subsidiaries HBHC does not give legal advice
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DISASTER RECOVERY RISKS LESSONS LEARNED
DISCLAIMER • The information contained in presentation represents generic industry information and does not express the views of Hancock Bank Holding Company (HBHC) or any of its subsidiaries • HBHC does not give legal advice • Any quotes, narratives or excerpts of information used with permission
Hurricane Katrina • Massive storm – YES. • Massive damage to several states – YES. • Massive problems for financial institutions – YES. • Massive changes to Disaster Recovery plans – YES. • Hurricanes aren’t the only disasters that can hit you – tornadoes, fires, flooding, and the list goes on and on – natural disasters as well as threats of terrorism
Disaster Recovery Plan • Just because you are in Trust / Wealth Management / Investments, do not think that your plan is a stand alone plan and you will not be affected. • We learned what really is the number one and most important step that should be in your Disaster Recovery plan – both pre-disaster and after.
MOST IMPORTANT STEPS • People • Communication • Location • Access to Essential Functions • Coordination with support areas • Testing
C O N T A C T L I S T S • Have in Disaster Plan every type of contact information that you can gather • Phone numbers for as many people in everyone’s family that you can – locally & away • Ensure that your contact lists in your plan are always current • Provide this list to all employees, whether considered key personnel or not • Make sure everyone understands that Disaster Recovery is a TEAM effort & everyone is included – these lists should always be with them or in a place they can access anytime
E M P L O Y E E S • Locate, locate, locate each & everyone you can as fast as you can • Ensure contact is made daily • Ensure everyone is kept in the “loop” – essential personnel or not • Have a location for your people to gather • Ensure that everyone knows where it is
E S S E N T I A L P E R S O N N E L • Ensure that there are back ups for all “key” personnel identified in your plan • Ensure that cross training has been completed for all “Critical” positions, including Supervisors as well as in Compliance • Ensure that during testing you include all of these identified in your plan
C O M M U N I C A T I O N • Steps to implement communication immediately • Deployment to another location and a SET time frame • Vendor 24/7 contacts • Transportation – Type, Fuel, Access • Mail service – Post Office, UPS, Fed Ex, etc.
L O C A T I O N • Assess the personnel you have available to work • IMMEDIATELY implement your compliance disaster recovery plan • Ask for help from everyone to ensure ALL areas are monitored & policy & procedures are followed • DOCUMENT any & all exceptions, whatever the reason
C R I T I C A L F U N C T I O N S • Assess what functions you deem most critical to operate in a disaster situation • Personnel essential to these functions • Location and steps to implement this part of your plan • Essential equipment, systems, supplies and files needed for these functions
C O O R D I N A T I O N • Other areas within your organization, vendors and outside suppliers • Contact names, numbers and addresses for all above • IT coordination whether service bureau or out-sourced or internal • Coordination of Disaster Recovery Plans • Copies of contracts or at least an except from contract
T E S T I N G • Identify back ups for all “key” personnel • Cross training completed for all “Critical” positions & functions • Include everyone identified in your plan • Set dates for testing & follow up on all exceptions • Be included in disaster recovery testing for all areas within your organization, vendors and outside suppliers
C O M P L I A N C E • Don’t lose sight of: • Due Diligence, Policy & Procedures • Internal Controls, Confidentiality • Reconcilements, Suspense Accounts • Passwords, Dual Custody • Asset Protection, Daily Administrative Duties • Settlements, Investments, Distributions • Your Role on Accounts, Customer Requests • Fiduciary Duty comes First
C O M P L I A N C E • Make sure whoever is responsible for Fiduciary Compliance has a good back up • If not responsible for Disaster Recovery plans, ensure you are part of the process for Wealth Management, all areas in your organization as well as vendors • Network with others in your area • Use resources available – anyone you can possibly think of
C O M P L I A N C E • Excerpts from HBHC (used with permission): • FUEL: Fuel plan to ensure that the lights and computers stay on as well as associates have fuel to get to work - designed to be self-sufficient for 10-days. • TECHNOLOGY SYSTEMS: Mainframe "host" and servers to include access to Email and VPN into the system from the Internet. • EMERGENCY NOTIFICATION: Alert24 notification system. • PHONES: The (service provider) phones programmed with a set of pre-determined contact numbers. Pre-issuance of some of the phones as primary communication devices for key associates. • KEY OFFICES: Identified key offices to support connectivity to the network that have manual transfer switches so we can support them with generator power without disrupting the (local electric company) power feed.
R E S O U R C E S • FFIEC Publication LESSONS LEARNED FROM HURRICANE KATRINA: Preparing Your Institution for a Catastrophic Event • ABA Task Force Policy on Emergency Preparedness
R E S O U R C E S • Emergency Agencies • American Red Cross(202) 303-4498 • NOAA/National Weather Service(301) 713-0622 • The Salvation Army(202) 289-4001 • Department of Homeland Security(202) 282-8000 • Federal Emergency Management Agency(800) 621-FEMA or (800) 621-3362 • Federal Regulatory Agencies • Federal Financial Institutions Examination Council • Federal Deposit Insurance Corporation(877) ASK-FDIC or (877) 275-3342 • Board of Governors of the Federal Reserve System(202) 452-3000 • National Credit Union Administration(703) 518-6300 • Office of the Comptroller of the Currency(202) 874-4700 • Office of Thrift Supervision(800) 958-0655 or (202) 906-6000
R E S O U R C E S • State Regulatory Agencies • Alabama State Banking Department (334) 242-3452 • Alaska Department of Community and Economic Development(907)465-2521 • Arizona Department of Financial Institutions(602) 255-4421 • Arkansas State Bank Department(501) 324-9019 • California Department of Financial Institutions(415) 263-8555 • Colorado Division of Banking(303) 894-7575 • Connecticut Department of Banking(860) 240-8299 • DC Department of Insurance, Securities, and Banking(202) 727-8000 • Delaware Office of the State Bank Commissioner(302) 739-4235 • Federated States of Micronesia Banking Board(691) 320-2015
R E S O U R C E S • Florida Office of Financial Regulation(850) 410-9800 • Georgia Department of Banking and Finance(770) 986-1633 • Guam Department of Revenue and Taxation(671) 475-1817 • Hawaii Division of Financial Institutions(808) 586-2820 • Idaho Department of Finance(208) 332-8000 • Illinois Dept. of Financial Regulation - Division of Banking(217) 785-2900 • Indiana Department of Financial Institutions(317) 232-3955 • Iowa Division of Banking(515) 281-4014 • Kansas Office of the State Bank Commissioner(785) 296-2266 • Kentucky Office of Financial Institutions(502) 573-3390
R E S O U R C E S • Louisiana Office of Financial Institutions(225) 925-4660 • Maine Bureau of Financial Institutions(207) 624-8570 • Mariana Islands Department of Commerce(670) 664-3008 • Maryland Commissioner of Financial Regulation (410) 230-6101 • Massachusetts Division of Banks(617) 956-1500 • Michigan Office of Financial & Insurance Services(517) 335-3167 • Minnesota Department of Commerce(651) 296-2135 • Mississippi Department of Banking and Consumer Finance(601) 359-1031 • Missouri Division of Finance(573) 751-3242 • Montana Division of Banking & Financial Institutions(406) 841-2920
R E S O U R C E S • Nebraska Department of Banking & Finance(402) 471-2171 • Nevada Financial Institutions Division(702) 486-4120 • New Hampshire Banking Department(603) 271-3561 • New Jersey Department of Banking and Insurance(609) 292-3420 • New Mexico Financial Institutions Division(505) 827-7103 • New York State Banking Department(212) 709-3501 • North Carolina Banking Commission(919) 733-3016 • North Dakota Department of Financial Institutions(701) 328-9933 • Ohio Division of Financial Institutions(614) 728-8400 • Oklahoma State Banking Department(405) 521-2782
R E S O U R C E S • Oregon Division of Finance and Corporate Securities(503) 378-4140 • Pennsylvania Department of Banking(717) 787-6991 • Puerto Rico Bureau of Financial Institutions(787) 723-8004 • Rhode Island Department of Business Regulation(401) 222-2405 • South Carolina Department of Consumer Affairs(803) 779-0850 • South Dakota Division of Banking(605) 773-3421 • Tennessee Department of Financial Institutions(615) 741-2236 • Texas Department of Banking(512) 475-1300 • Utah Department of Financial Institutions(801) 538-8830 • Vermont Department of Banking and Insurance(802) 828-3307
R E S O U R C E S • Virgin Islands Division of Banking and Insurance(340) 774-7166 • Virginia Bureau of Financial Institutions(804) 371-9657 • Washington Department of Financial Institutions(360) 902-8704 • West Virginia Division of Banking(304) 558-2294 • Wisconsin Department of Financial Institutions(608) 261-9555 • Wyoming Division of Banking(307) 777-7797 • Conference of State Bank Supervisors(202) 296-2840
R E S O U R C E S Printable Format of Emergency Contact Information - PDF Neighborhood (Local) Contact Name____________________________________________________ Work_________________________Home_____________________________ Address________________________________________________________ City,ST_________________________________________________________ Out-of-State Contact Name____________________________________________________ Work_________________________Home_____________________________ Address________________________________________________________ City,ST_________________________________________________________ Emergency Notification Who do we notify if something happens to you? Contact Name____________________________________________________ Work_________________________Home_____________________________ Address________________________________________________________ City,ST_________________________________________________________