COVID-19 Operational Risk Assessment and Mitigation

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COVID-19 Operational Risk Assessment and Mitigation - Part 1

For smaller mortgage and consumer lending entities. Completing this assessment will provide a report that can be submitted to regulators as to your actions related to Novel Coronavirus (COVID-19).

Generally, when preparing this report, you will be required to collect and submit data. Some data involves separate questionnaires or checklists which you must complete. ALL EXHIBITS must be provided in graphic format.

Since all responses to this assessment must be provided in graphic format, PLEASE ensure that you have some sort of screen capture or image printing software. You can capture images using simple desktop components like "prt sc" the print screen button on most keyboards, and pasting the image to the "paint" utility to crop or redact confidential information.

Email *

Company Name

Provide the Company's legal name. This will be the name that appears in your report.

Compliance Manager Name

Preventative Measures: Virtual Workplace

According to the US Department of Labor, during an epidemic the primary defense for any firm involves avoiding group contact of any sort. We facilitate this through our ability to work remotely and our policies encourage remote work.

Our employees are allowed to work remotely

We have a system to track employee hours and productivity when working remotely

We have a conference call vendor to conduct meetings remotely

Customer contact can be conducted virtually

We have tested all remote connections and know that, even in periods of high load, our employees can connect to resources via network

We have established a method of communicating with all employees and counterparties regarding pandemic evolution and response

Our telephony provider allows us to remote call forward to specific numbers so that the main office number may be unattended

Vendor Risk Management

When adding vendors to our roster, such as lenders, brokers, appraisal firms, title companies and others, we require them to have remote or virtual services

We require all vendors to provide definitive time frames for delivery of products or services at all times, but especially during disasters

Do any contracts include "Force Majeure" the ability to negate a contract due to forces outside of control

Do your insurance policies - errors and omissions - cover losses due to pandemic

Do leases include ability to cancel due to force majeure

Communications

We communicate with our customers by posting updates on pandemic impacts prominently on our website

We communicate with actively processing customers by sending emails

We communicate with our employees by sending emails

We communicate with our employees using a group chat feature

IT Theft Increased Risk from Employees working at home

We provide a VPN to protect public access to data over WiFi

We provide a secure router for the use of employees who will use cabled computers

We validate Firewall security on all computers and routers which will be used for company business

We provide a physical shredding service to ensure paper documents do not get compromised

We do not allow individuals to store paper documents and files in their home location

Staging

1-Our initial response is to notify all parties of an event

2-We initiate the business continuity plan

3-If critical infrastructure or partners become unavailable we seek additional resources

4-We will adjust our finances to conserve capital and preserve critical infrastructure and personnel

5-We will suspend business operations if necessary, at the request of the government

6-If we no longer intend on operating we will notify our regulators of business cessation

Workplace Preventative Measures

Our personnel policies requires that employees who are sick stay at home

During epidemics, we post signs that encourage hand washing

During epidemics, we provide hand sanitizers and disinfectant wipes to allow employees to keep their work spaces and other surfaces clean

During epidemics, we do not have onsite meetings

Our personnel policies include encouraging wellness, such as smoking cessation

We stockpile antiseptic supplies

We require immune-compromised employees such as diabetics and pregnant employees to stay away from the workplace

We suspend business travel

Servicing and Payment Collection

We receive updates from Federal and State Agencies and during disasters, extend disaster declaration benefits to those customers

We have a policy that waives late payment fees and other loss mitigation efforts

We post information on our website for customers who may have difficulty making payments

Critical Employees

We have identified critical employees

In the event of business cessation, we have provisions to continue to compensate key employees

Name of Critical Employees - Complete short answer text as follows:

1- Compliance (Name) 2 - Sales (Name) 3 - Processing/Underwriting Closing (Name) 4 - Secondary Marketing (Name) 5 - IT (Name)

Regulatory Compliance - We have evaluated and met the demands of all licensing authorities with respect to COVID-19

NY Preventative Measures

NY Documented Staging Strategy

NY Facilities and Infrastructure Assessment

NY MI Potential for Increased Cyber-security Threats

NY Employee Protection Strategies

NY Assessment of Third Parties

NY MI Communication Plan

NY Testing the Communication Plan

NY Testing the Disaster Recovery Plan

MI Are we reducing staff or services

MI Implemented a remote workforce strategy

MI Communicated with Customers

MI Published Problems Making Payments

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