The OGO Blog

What Does the NCUA Require from a Credit Union Business Continuity Plan?

Are you getting ready to do some business continuity planning (BCP)? Does your credit union need a little guidance on where to start and what you’ll need? In this blog, we’ll run through some of the basic NCUA requirements for your credit union’s business continuity planning efforts.

This guide shouldn’t serve as an official source. Please double check the NCUA business continuity planning requirements before checking this item off your to-do list.

Nevertheless, if you’re trying to get in the ballpark, or if you want to see what you’re getting yourself into, this is the place to start.

The Five Things Your Credit Union’s Businesses Continuity Plan Really Needs

If we were to distill your credit union’s business continuity planning needs down to their essences, what would you need?

Well, in our estimation, these are the five things that you really shouldn’t do without. Make sure you’ve got these areas covered in your credit union’s business continuity plan.

1.    Business Impact Analysis (BIA) Report

Your business impact analysis report defines your business processes. It also assesses what the effect on your credit union would be if those processes were disrupted.

(If you’d like to learn more about credit union business impact analyses, just click that link!)

2.    Risk/Threat Assessment Survey

The threat assessment survey helps you develop mitigation plans for threats that you deem highly likely. You will also need plans for scenarios that would have a very high negative impact to your credit union.

(You can read more about credit union risk assessment here.)

3.    Recovery Action Steps

Another component of credit union business continuity planning that the NCUA will require are recovery action steps. It’s not enough for you to say that you understand the risks involved—you have to actually show how you will recover from any business impacts.

Recovery action steps will be twofold. First, you’ll need higher-level infrastructure recovery steps for the Crisis Management Team. Second, you’ll need departmental recovery steps so that your individual business departments can also return to their normal working order as quickly as possible.

(If you want to read about putting together a credit union recovery action template, we’ve got you covered.)

4.    Recovery Time Objectives

There’s an old joke that’s made its way onto countless mugs, signs, shirts, and sundry. It goes like this:


The idea is that it’s not very useful to have a plan for fixing something if you never get around to fixing it. Recovery time objectives keep your efforts on track. They let you, the FFIEC, and the NCUA know that you’re actively working toward the completion of a goal.

(As you probably guessed, we have a little something to read about credit union recovery time objectives as well.)

5.    Disaster Recovery Testing

One of the things that the NCUA examiners and auditors will look at is your disaster recovery testing. They want to see that you’ve actually done a disaster recovery test and haven’t just, like, “considered” it, however thoroughly.

Disaster recovery testing is an important part of business continuity planning. However, if you’re looking for something to better differentiate the two, we can slip back into our handy italics for a second.

(Here are the italics, and here is where you can read about credit union business continuity planning vs disaster recovery.)

Additional Reading

Those five considerations should get you well on your way toward completing a successful credit union business continuity plan. More importantly, they should get you well on your way toward satisfying any NCUA requirements.

To read more about credit union business continuity planning, subscribe to our blog! We keep it pretty stocked with (hopefully) useful information about how to maintain operations through the thick of it all.

Or if you’re feeling particularly curious, you can follow the links below.

3 Tips for Maintaining Credit Union Business Continuity Plans

Credit Union Business Continuity Planning vs. Disaster Recovery: What’s the Difference?