The following is an article written by Optiri's Director, Business Continuity Management, Tim Daugherty. It originally appeared on CUInsight.com.
In today’s risk landscape, business continuity planning is no longer optional, it’s a regulatory expectation and a strategic necessity. Yet many credit unions operate under the false sense of security that simply having a business continuity plan (BCP) on file is enough. The truth is, if your BCP is outdated or untested, your credit union could be exposed to serious operational, reputational, and regulatory risks.
Here are five warning signs that your BCP may not be ready for a real disruption:
1. It Hasn’t Been Updated in Over a Year
Regulatory bodies like the NCUA and FFIEC expect your BCP to reflect your current operations, systems, staffing, and vendor relationships. If your plan hasn’t been reviewed and updated in the last 12 months or after major changes to your infrastructure, you’re likely relying on inaccurate information. That’s a dangerous gamble in an emergency.
What to do: Schedule an annual review and establish a process to update your plan after significant operational changes.
2. Staff Don’t Know Their Roles During a Disruption
A BCP is only effective if the people responsible for executing it know what to do. If your employees aren’t aware of their specific roles in an incident, or worse, don’t even know if a plan exists, your recovery timeline could spiral out of control.
What to do: Incorporate BCP roles into onboarding, refresher training, and regular tabletop exercises to reinforce awareness.
3. You Haven’t Tested It
An untested plan is an unproven plan. If you’ve never conducted a tabletop exercise or live simulation, you don’t know how your credit union would really perform under pressure. Testing reveals critical gaps in communication, decision-making, and coordination.
What to do: Schedule at least one annual BCP exercise and vary the scenario (e.g., cyberattack, natural disaster, vendor outage). Document lessons learned and revise the plan accordingly.
4. It’s Too Complex to Use in a Crisis
Lengthy, jargon-filled documents may satisfy an auditor, but they’re rarely helpful during an actual emergency. If your plan is difficult to navigate or too long to act on quickly, it won’t serve your team when time and clarity matter most.
What to do: Create quick-reference guides, role-based playbooks, and checklists that distill key actions into clear, usable formats.
5. Your Vendors Are Missing From the Plan
Many credit unions rely on third-party vendors for core processing, communications, or cloud services. If your BCP doesn’t include how you’ll respond to a vendor failure or validate that your vendors have recovery plans of their own, you’re exposed to a serious continuity blind spot.
What to do: Review contracts for vendor BCP language, and include critical vendors in your plan, testing, and risk assessments.
Take the Next Step
An outdated or poorly executed BCP won’t protect your members, your team, or your reputation when disaster strikes. Don’t wait for a disruption to test your readiness.
If you’re unsure where to begin, consider a professional BCP assessment to identify quick wins, close critical gaps and ensure your credit union is resilient, compliant and truly prepared.
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