2006-07-05

OFI Bulletin 02a-2006 Emergency Preparedness for Banks

The Office of Financial Institutions issued this bulletin to require all banks and thrifts to implement comprehensive disaster planning for the 2006 hurricane season. Institutions must maintain updated emergency contact information for their disaster recovery teams and coordinate with local parish sheriff and emergency preparedness offices to secure re-entry credentials for employees and vehicles. The directive emphasizes obtaining specific documentation, such as company or InfraGard identification and business purpose letters, to ensure uninterrupted operations and secure access when services are limited following a catastrophic event.

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OFI BULLETIN BL-02a-2006 (B,T) June 21, 2006 TO: ALL CEOs OF BANKS AND THRIFTS FROM: JOHN DUCREST, COMMISSIONER SUBJECT: DISASTER PLANNING FOR THE 2006 HURRICANE SEASON An interagency publication entitled, “Lessons Learned from Hurricane Katrina: Preparing Your Institution for a Catastrophic Event,” was released on June 15, 2006. Please take the time to view this document, located at http://www.ffiec.gov/katrina_lessons.htm , as part of your preparation for the upcoming hurricane season. Some very good tips are included in the booklet. [NOTE: If you have trouble finding or printing out the document, please call Beverly Patin at 225/922-0635, and she will mail you a hard copy of the booklet.]

In our annual questionnaire sent out earlier this year, we requested and have compiled primary and secondary emergency contact information for your disaster recovery team that would only be used in the event of an emergency such as the 2005 hurricanes. It is expected that the disaster recovery team will maintain emergency contact information for the board and senior management. Please notify this office immediately if your disaster recovery team information changes. If you have not already provided us with this information, please contact Administrative Specialist Donna Montagnino at (225) 925- 4483 or by email at dmontagnino@ofi.louisiana.gov as soon as possible. In our year-end mail-out, we also included a card with vital contact information for key individuals within this office. We have enclosed three new, laminated cards with this same information. Senior staff should maintain a copy of this card to contact this office and provide updated disaster recovery information for your institution. If you need to contact OFI, anyone on the OFI card, including any of the district office managers, may be contacted if you are unable to reach someone at the Main Office. This Office has been assigned to several emergency support functions within the Governor’s Office of Homeland Security and Emergency Preparedness (GOHSEP). In the event that we have to deal with another wide-area disaster, we will receive information through the GOHSEP. This information will then be shared with the industry through frequent conference calls, emails, and postings to our website at www.ofi.louisiana.gov. OFFICE OF FINANCIAL INSTITUTIONS

2 Recently, this Office and the Louisiana Bankers Association participated in a number of Hurricane Preparation Meetings at locations across the southern portions of the state. One of the key things that we learned during these meetings was that every parish will be different in its requirements to re-enter the area after an evacuation when significant destruction is present. The GOHSEP is trying to establish uniform minimum requirements for each parish to request, but the minimum requirements for statewide re-entry may not be finalized for this hurricane season. In the meantime, every parish is different in their precise requirements. In addition, while all parishes have a sheriff’s office and an emergency preparedness office, we have found that they are entirely different agencies, sometimes run by different people, and may have different requirements for re-entry. We recommend that all banks/thrifts contact the sheriff’s and emergency preparedness offices for every parish in which you have a location or that you would need to enter to get to a location, maintain a contact name and phone number for each, and find out how to get on their list of responders that are allowed to re-enter after the area has been declared safe for critical businesses to return. It was stressed that you need to be conservative in the number of employees that you request permission for re-entry and that those allowed to re￾enter specifically deal with business pertaining to the institution. Every person should have the necessary credentials or the entire vehicle has a chance of being denied entry. If you find that your parish does not have specific requirements for re-entry, we would suggest that, at a minimum, the following credentials be maintained. If your parish has specific requirements, of course, you would have to abide by its requirements.

  1. A valid driver’s license
  2. A company ID with picture [NOTE: If you are not comfortable providing non￾company employees, such as vendors or contract workers, with a company ID, these individuals may get an InfraGard ID through the FBI. A website with more information is www.infragard.net.]
  3. Letter on company letterhead that identifies the business purpose for each employee’s re-entry
  4. Letter on company letterhead and with identifying numbers for car that authorizes that vehicle as a critical infrastructure vehicle and names the specific business purpose to re-enter The employees who re-enter a devastated area are reminded that services such as electricity, phone, water, food, gasoline, supplies, security, or hospital/emergency services may be limited or non-existent; therefore, they should be able to sustain themselves and not expect to rely on the emergency workers who are trying to get the area ready for the general public to return. In the aftermath of Hurricanes Katrina and Rita, in some cases, gasoline and diesel fuel were confiscated by authorities when financial institutions were trying to truck it in for their generators. Also, security for returning employees should be a high priority.

3 It is my ardent hope that nothing like the hurricanes of 2005 will ever happen again to anyone, anywhere, but we’d prefer that everyone is prepared, just in case. If you have any questions, please contact Chief Examiner Sid Seymour at 225/925-4675 or sseymour@ofi.louisiana.gov or me at 225/922-2627 or jducrest@ofi.louisiana.gov.