June 2022 

CIGFO-2022-01

Council of Inspectors General 

on Financial Oversight

Guidance in Preparing for and

Managing Crises

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iii Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Table of Contents 

Table of Contents
 

Transmittal Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
 

Guidance in Preparing for and Managing Crises . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
 

Collaboration and Pre-Crisis Planning Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
 

Agencies’ Crisis Readiness Plan Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
 

Agencies’ Crisis Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
 

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
 

APPENDIX I: Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13
 

APPENDIX II: FSOC Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14
 

APPENDIX III: Sources Used by the CIGFO Working Group to Develop Guidance . . . . . . . . . . . .16
 

APPENDIX IV CIGFO Working Group . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
 
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v Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

June 2022 

The Honorable Janet Yellen 

Chair, Financial Stability Oversight Council 

Washington, D .C . 20220 

Dear Madam Chairwoman: 

I am transmitting to you the Council of Inspectors General on Financial Oversight (CIGFO) 

report titled, CIGFO Guidance in Preparing for and Managing Crises

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) 

authorizes CIGFO to convene working groups of its members to address issues within its 

jurisdiction . Accordingly, CIGFO convened a Working Group in August 2020 to compile 

forward-looking guidance for the Financial Stability Oversight Council (FSOC) and its 

members to consider in preparing for and managing a crisis . This effort was undertaken at a 

critical time in our nation, precipitated by the COVID-19 pandemic . 

This guidance is intended to be a compilation of lessons learned drawn from the experiences 

of federal agencies during prior crises and any learned during the current pandemic . This 

forward-looking guidance will facilitate effective crisis response as FSOC fulfills its mission 

to identify threats to the financial stability of the country, promote market discipline, and 

respond to emerging threats to the stability of the U .S . financial system . 

This guidance does not assess the degree to which the FSOC member agencies employ 

any of the actions presented herein . Rather, the purpose of this guidance is to compile 

information and activities that agencies and CIGFO Offices of Inspector General identified as 

integral to pre-crisis planning and crisis management so that FSOC and its member agencies 

can evaluate its existing efforts and initiate new ones, as needed, consistent with each 

organization’s mission . We are not making any recommendations to FSOC as a result of this 

effort . 

I would like to take this opportunity to thank the FSOC members for their support, especially 

those Treasury officials who assisted with this effort . 

CIGFO looks forward to working with you on this and other issues . In accordance with the 

Dodd-Frank Act, CIGFO is also providing this report to Congress . 

Sincerely, 

/s/ 

Richard K . Delmar 

Acting Chair, CIGFO 

Deputy Inspector General, Department of the Treasury 
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1 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

Guidance in Preparing for and 


Managing Crises
 

The Council of Inspectors General on 

Financial Oversight (CIGFO) provides 

oversight of the Financial Stability Oversight 

Council (FSOC) . CIGFO members include 

nine Inspectors General (IG) with oversight 

authority for the federal member agencies 

of FSOC .1 In August 2020, CIGFO convened 

a Working Group to develop guidance for 

FSOC and its member agencies to consider 

in preparing for and managing future crises . 

CIGFO derived this guidance from the 

crisis response experiences of both the 

contributing CIGFO Office of Inspector 

General (OIG) Working Group members 

(CIGFO Working Group) and the federal 

agencies they oversee .2 CIGFO OIGs 

identified practices and lessons learned by 

their respective agencies from prior crises 

and the current pandemic .3 The CIGFO 

Working Group analyzed these submissions 

and summarized the practices and lessons 

learned from the financial regulators into this 

guidance . In addition, the Working Group 

reviewed previous reports issued by the 

International Monetary Fund (IMF) and the 

U .S . Government Accountability Office (GAO) 

regarding crisis preparedness actions and 

recommendations for FSOC . The Working 

Group also interviewed FSOC officials . This 

guidance does not assess the degree to 

which the FSOC member agencies employ 

any of the actions presented herein . Rather, 

the purpose of this guidance is to compile 

information and activities that agencies 

and OIGs identified as integral to pre-crisis 

planning and crisis management so that 

FSOC and its member agencies can evaluate 

their existing efforts and initiate new ones, as 

needed, consistent with each organization’s 

mission . 

In 2010, in the wake of the 2007-2009 Great 

Recession, the Dodd-Frank Wall Street 

Reform and Consumer Protection Act (DoddFrank Act) was enacted to “promote the 

1 The nine CIGFO members include the Inspectors General from the Board of Governors of the Federal Reserve System (FRB), 

Commodity Futures Trading Commission (CFTC), U .S . Department of Housing and Urban Development (HUD), Department of the 

Treasury (Treasury), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), National Credit Union 

Administration (NCUA), Securities and Exchange Commission (SEC), and the Special Inspector General for the Troubled Asset Relief 

Program (SIGTARP) . 

2 The Working Group project was performed in accordance with CIGIE’s Quality Standards for Federal Offices of Inspector General 

(Silver Book) . These quality standards, as contained in the Agile Products Toolkit https://www .pandemicoversight .gov/media/file/ 

agile-products-toolkit0pdf), include independence, analysis, evidence review, indexing and referencing, and supervision . 

3 The CIGFO Working Group collected information from the OIGs for the FRB (including information relating to the Consumer 

Financial Protection Bureau (CFPB)), CFTC, Treasury, FDIC, FHFA, NCUA, SEC, and SIGTARP . 
2 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

financial stability of the United States .”4 As 

a part of this effort, the Dodd-Frank Act 

created the FSOC, whose members include 

the federal financial regulatory agencies .5 The 

Act conferred upon FSOC the authority to 

respond to emerging threats and to identify 

risks to the financial stability of the United 

States .6 To meet these responsibilities, the 

Dodd-Frank Act assigned FSOC with, among 

other duties: (1) collecting information from 

member agencies; (2) facilitating information 

sharing and coordination among the member 

agencies; and (3) recommending to the 

member agencies general supervisory 

priorities and principles that reflect member 

agency discussions .7 

During the past two years, FSOC has served 

as a forum for federal and state regulators 

to collect information, analyze risks, share 

information, and coordinate their responses 

to the economic shock caused by the 

Coronavirus Disease 2019 (COVID-19) .8 

However, FSOC’s coordination role is not 

limited to responding to emerging threats, 

such as COVID-19 . FSOC is also authorized 

to identify risks to the United States’ 

financial stability that could arise outside of 

the financial services marketplace, such as 

those that could arise from a future crisis . 

FSOC has an opportunity to serve in this 

coordination role by collecting and sharing 

information relating to crisis preparedness 

and then identifying the risks to the financial 

stability of the United States associated 

with the failure to prepare for future crises . 

Using this coordination role to focus on 

crisis preparedness and identifying risks 

associated with agencies’ crisis preparedness 

is a role that FSOC has not undertaken -- 

notwithstanding multiple recommendations 

by different oversight authorities . 

For example, both the IMF and GAO have 

recommended that FSOC enhance its 

crisis preparedness role . In 2015, the IMF 

recommended that FSOC assume a formal 

crisis preparedness and management 

role . This recommendation remains 

unimplemented, and the IMF reiterated this 

recommendation to FSOC in its August 2020 

United States Financial System Stability 

Assessment 9 In addition, GAO recommended 

in a December 2020 report that FSOC 

conduct scenario-based exercises intended 

to evaluate capabilities for responding to 

crises .10 FSOC neither agreed nor disagreed 

with the GAO recommendation . On January 

4 Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub . L . No . 111-203, 124 Stat . 1376 (2010) . 

5 FSOC is composed of 15 members: 10 voting members and 5 nonvoting members . Voting members include the chair of FSOC 

(Treasury Secretary); heads of FDIC, FRB, OCC, NCUA, SEC, CFTC, FHFA, and CFPB; and an independent insurance expert 

appointed by the President . Nonvoting members include the directors of Treasury’s Office of Financial Research (OFR) and Federal 

Insurance Office (FIO), and state regulatory representatives, one each for insurance, banking, and securities . 12 U .S .C . § 5321 . 

6 Section 112(a)(1) of the Dodd-Frank Act, 124 Stat . at 1394 (codified at 12 U .S .C . § 5322(a)(1)) . 

7 Section 112(a)(2) of the Dodd-Frank Act, 124 Stat . at 1395 (codified at 12 U .S .C . § 5322(a)(2)) . 

8 Treasury Department, Press Release, Financial Stability Oversight Council Releases Annual Report (Dec . 3, 2020) . 

9 International Monetary Fund, United States Financial System Stability Assessment (August 2020) at 80, App . VII at 105 (reiterating 

the 2015 IMF recommendation to assign a formal crisis preparedness and management coordinating role to FSOC and noting that 

the earlier recommendation remains unimplemented) . 

10 U .S . Government Accountability Office, Financial Stability: Agencies Have Not Found Leveraged Lending to Significantly Threaten 

Stability but Remain Cautious Amid Pandemic (GAO-21-167) (Dec . 2020) at 58 . 
3 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

 

26, 2021, the CIGFO Working Group 

requested information regarding the actions 

that FSOC had taken or intended to take to 

address the IMF and GAO recommendations . 

Subsequent to the issuance of a Discussion 

Draft of this guidance on June 7, 2021, FSOC 

informed the CIGFO Working Group that it 

was in the process of compiling its Article 

IV responses to the IMF recommendations11 

and would share them with the CIGFO 

Working Group when the IMF report is 

published . On July 22, 2021, FSOC shared the 

U .S . Authorities’ Article IV responses12 with 

the CIGFO Working Group . FSOC asserted 

that its role “is not intended to serve as the 

primary responder during times of financial 

crisis . Rather, its purpose is to identify 

potential vulnerabilities and emerging 

threats to financial stability, and to develop 

recommendations for addressing those risks .” 

On June 14, 2021, FSOC also reiterated its 

earlier statements regarding the GAO report 

(December 2020)13 in letters to various 

congressional committees but did not 

describe any additional specific actions that 

FSOC had initiated or intended to initiate to 

address the GAO recommendation .14 

FSOC and its member agencies have an 

opportunity to work together to plan for 

future crises . Our guidance outlined herein 

can serve as a reference tool for both FSOC 

and its member agencies . For FSOC, this 

information can be used to assist in fulfilling 

its coordination role and to help it identify 

risks to the financial stability of the United 

States by considering: (1) the type of crisis 

planning materials that are available for 

collection and dissemination to and from 

member agencies, (2) the threats posed to 

the United States’ financial stability relating 

to potential gaps in crisis planning activities, 

and (3) the appropriateness of prioritizing 

crisis planning, consistent with member 

agencies’ discussions . For member agencies, 

this guidance provides information about 

crisis readiness practices that can be used to: 

(1) reinforce and supplement current crisis 

readiness practices; (2) identify potential 

gaps in current crisis readiness plans; and (3) 

assist in designing and managing future crisis 

programs . 

11Under Article IV of the IMF’s Articles of Agreement, the IMF holds bilateral discussions with members, usually every year . FSOC’s 

Article IV responses are included in the IMF report . 

12 International Monetary Fund, United States 2021 Article IV Consultation – Press Release; Staff Report; and Statement by 

the Executive Director for the United States (July 2021); Appendix IV “Implementation of 2020 FSAP [Financial Sector 

Assessment Program] Recommendations” contains the U .S . Authorities’ self-assessment of the status of implementation for the 

recommendations of the 2020 FSAP and is not necessarily the assessment of IMF staff . https://www .imf .org/en/Publications/CR/ 

Issues/2021/07/22/United-States-2021-Article-IV-Consultation-Press-Release-Staff-Report-and-Statement-by-the-462540 

13 The GAO report recommended that FSOC, in consultation with its members, “should incorporate regular scenario-based exercises 

designed to evaluate individual FSOC member and collective capabilities for responding to crises into its risk-assessment activities . 

These could include tabletop exercises that assume increased financial risks under plausible macroeconomic and financial 

conditions that may require multiple regulators to respond .” GAO, Financial Stability: Agencies Have Not Found Leveraged Lending 

to Significantly Threaten Stability but Remain Cautious Amid Pandemic, at 58 (GAO-21-167) (December 2020) . In its December 2020 

response to the GAO recommendation, FSOC explained that it leverages the work and expertise of its member agencies (i .e ., heads 

of federal and state financial regulatory agencies) and that a number of financial regulators organize tabletop exercises in which 

FSOC staff regularly participate . FSOC further noted that it initiates additional activities, beyond those of its individual member 

agencies, including rigorous analyses for interagency discussion . Id . at 82 . 

14 Instead, FSOC’s correspondence to six congressional committees reiterated that it participates in tabletop exercises organized 

by its member financial regulators and engages in independent activities to supplement the work of member agencies, including 

generating rigorous analyses for interagency discussion . 
4 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

 

 

Guidance in Preparing for and Managing Crises 

Prudent crisis preparedness can help 

agencies manage an array of potential 

crises . According to the World Economic 

Forum, risks that could affect the world 

economy and the financial stability of the 

United States include environmental risks 

caused by extreme weather events such 

as floods and hurricanes; natural disasters 

such as earthquakes and tsunamis; climate 

change that could amplify credit, liquidity, 

and counterparty risk that challenge financial 

management; technological risks such as 

large-scale cyberattacks or malware causing 

economic damages; violent protests; and 

geopolitical risks such as terrorist attacks 

and the deployment of nuclear, chemical, 

biological or radiological weapons .15 At the 

FSOC meeting on March 31, 2021, the Chair of 

FSOC, the Secretary of the Treasury, stated 

during the Open Session: 

Climate change is obviously 

the big one . It is an existential 

threat to our environment, and 

it poses a tremendous risk to 

our country’s financial stability .

 . . . Our financial system must 

be prepared for the market and 

credit risks of these climaterelated events . . . . On all these 

fronts, the [Financial Stability 

Oversight] Council has an 

important role to play, helping 

to coordinate regulators’ 

collective efforts to improve the 

measurement and management 

of climate-related risks in the 

financial system .16 

Such events could lead to the disruption of 

key infrastructure elements for extended 

periods of time, including: 

•	 Limited or no electrical power, 

•	 Limited or no email or internet
 

communications,
 

•	 Disrupted food and water supplies, 

and 

•	 Disrupted transportation routes . 

In particular, the current COVID-19 pandemic 

environment has highlighted the financial 

system’s reliance on electrical and cyber 

connections where human contact is limited . 

It is important for FSOC and the financial 

regulators to be able to respond to such 

emerging threats, but also be prepared to 

identify risks that may exist relating to the 

organizations’ overall crisis preparedness . 

The crisis preparedness and management 

practices identified and summarized by 

the CIGFO Working Group OIGs were 

based upon agency planning documents to 

address market disruptions; contingency and 

crisis plans; stress tests; testing of market 

coordination procedures; retrospective 

analyses of regulator responses to prior 

crises; business resiliency management 

analyses; a prioritized supervision framework 

15 The World Economic Forum is an international organization established in 1971 for public-private cooperation . The Global Risks 

Report 2018 identified a list of hazardous risks that could affect the world economy and thereby potentially affect insured 

depository institutions . 

16 Secretary Janet L . Yellen, Financial Stability Oversight Council meeting (Mar . 31, 2021) https://home .treasury .gov/news/pressreleases/jy0092
5 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

in response to the COVID-19 pandemic; 

crisis management plans; economic impact 

analyses following a crisis; plans for cyber 

incident response; lesson learned reviews; 

strategic plan initiatives to improve crisis 

management and response capabilities; 

audits of agency responses to emerging 

risks; international peer reviews of agency 

approaches to supervision and regulation 

following financial crises; and audits to assess 

regulatory activities under Presidential Policy 

Directive 21 .17 The guidance derived from 

these sources broadly fall into the following 

categories: 

1 . 	 Collaboration and Pre-Crisis Planning 

Activities 

•	 Define agency mandates, roles, and 

responsibilities 

•	 Facilitate information sharing
 

proactively
 

•	 Strive for a shared view of market 

conditions 

•	 Implement continuous monitoring 

activities 

2 . 	 Agencies’ Crisis Readiness Plan Elements 

•	 Establish individual roles and
 

responsibilities related to plans
 

•	 Describe triggering events 

•	 Identify relevant legal authorities and 

tools, and potential emergency actions 

•	 Develop communication plans and 

options 

•	 Prioritize system capacity, and cyber 

and information security (aligned with 

existing continuity capabilities) 

•	 Provide for testing, evaluation, review, 

revision, and training 

•	 Provide for reporting 

3 . 	 Agencies’ Crisis Management 

•	 Implement leadership response 

•	 Coordinate among member agencies 

•	 Communicate to internal and external 

stakeholders 

•	 Assess resources 

•	 Supervise markets and regulated 

entities 

•	 Deploy response programs 

•	 Evaluate lessons learned 

CIGFO intends this guidance to assist FSOC 

and its member agencies with coordinating 

and planning for future crises in order to help 

identify and mitigate risks to the financial 

stability of the United States associated with 

potential gaps in crisis preparedness . We 

provide this guidance in support of FSOC 

and its member agencies’ ongoing efforts, 

recognizing that some activities are already 

broadly in practice, while other activities 

presented here can promote new initiatives 

that enhance the wider crisis planning effort . 

A list of the documents collected from the 

FSOC federal member agencies and their 

OIGs that were considered by the CIGFO 

Working Group in compiling the guidance is 

provided in Appendix III . 

17 The Presidential Policy Directive 21, released on February 12, 2013, established a national policy on critical infrastructure security and 

resilience, which is a shared responsibility among federal, state, local, tribal, and territorial entities, and public and private owners 

and operators of critical infrastructure . The policy’s goals are to enhance overall coordination and collaboration and clarify the 

functions, roles, and responsibilities related to critical infrastructure . 
6 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

Collaboration and Pre-Crisis 

Planning Activities 

A proactive crisis readiness effort involves 

working collaboratively to coordinate crisis 

readiness efforts across federal and state 

agencies and consulting with international 

agencies and organizations as needed . Precrisis preparations rely on: (1) identifying 

risks and conducting scenario analyses 

on options for how best to contain them 

before they escalate into crises, and (2) 

developing plans ahead of time that outline 

how an agency will respond to crises in 

case they materialize, known as crisis 

readiness planning . Member agencies may 

have different but overlapping missions, 

goals, responsibilities, and communication 

strategies . For these reasons, pre-planning 

and coordination among FSOC members is 

critical and includes the following actions: 

•	 Define Agency Mandates, Roles, 

and Responsibilities . Having a welldefined mandate and clear roles and 

responsibilities ensures the broad 

coverage of different risk categories 

while preventing the duplication of 

agency efforts, both prior to and 

during a crisis . Clarity in such roles and 

responsibilities is critical, especially 

because of the complexity and 

overlapping responsibilities among FSOC 

member agencies . Documenting and 

understanding agency mandates and 

roles during pre-crisis planning can assist 

FSOC and member agencies in conveying 

consistent messages to regulated entities 

during a crisis . 

•	 Facilitate Information Sharing Proactively. 

Promoting proactive information sharing 

relating to crisis preparations among 

the agencies facilitates coordination and 

prevents duplication of efforts . 

•	 Strive for a Shared View of Market 

Conditions. Striving to share a 

common view of the overall condition 

and risks within the financial markets 

is essential (including as emerging 

risks are identified) . Coordination of 

interdisciplinary subject matter experts 

enables agencies to: (1) take a holistic view 

of oversight areas and associated risks; 

(2) develop focused guidance; (3) share 

information across internal and external 

components; and (4) communicate 

consistently when a crisis arises . 

•	 Implement Continuous Monitoring 

Activities. Monitoring vulnerabilities to 

the stability of the U .S . financial sector is 

critical .18 The goal of pre-crisis monitoring 

activities in preparing for a crisis is to 

limit and mitigate risks . Such monitoring 

activities include: 

»	 Establishing risk committees to 

proactively evaluate risks to the 

financial system by capturing the 

collective views of multiple agencies, 

categorizing risks by severity, and 

reporting the consensus perspective 

18 Financial Stability Oversight Council, Department of the Treasury, 2020 Annual Report (2020) . 
7 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

throughout the FSOC community; 

»	 Conducting market surveillance to 

monitor for market disruption risk and 

requiring regulated entities to disclose 

market disruptions;19 

»	 Monitoring and updating counterparty 

credit risk to enable FSOC and 

member agencies to quickly and 

accurately assess risk exposures; 

»	 Performing stress tests to identify 

sources of strain and establish 

strategies for addressing liquidity 

shortfalls in emergencies; 

»	 Generating risk assessments that 

account for a range of crisis scenarios 

that could affect financial stability and 

their impact and probability; and 

»	 Conducting supervisory reviews of 

regulated entities’ preparedness and 

resilience to crisis events .20 

Thereafter, using the results of these 

monitoring activities helps to identify the 

array of risks to be addressed in crisis 

readiness plans . 

Agencies’ Crisis Readiness Plan 

Elements 

Crisis readiness plans outline how an agency 

will operate in, and respond to, an array 

of crisis scenarios . Crisis readiness plans 

create an overarching crisis management 

framework for strategic decision making, 

communication, and coordination . Such a 

plan or management framework can include: 

(1) an agency-wide, all-hazards readiness 

plan, and (2) agency-wide hazard-specific 

readiness plans, as needed, that integrate 

divisional plans containing requirements 

unique to certain types of crises . Effective 

crisis readiness planning includes input 

from and consultation with relevant agency 

stakeholders . Some agencies have made 

crisis preparedness an explicit goal in their 

strategic plans . At a minimum, these plans 

achieve greater impact when they include 

the following elements: 

•	 Establish Roles and Responsibilities. 

Identify and establish the roles and 

responsibilities of the individuals and 

groups involved in a crisis response . 

This includes identifying a high-level 

crisis leadership team and describing 

its responsibilities . A crisis leadership 

team that includes an organization’s 

senior leadership can achieve greater 

impact . This team is equipped with both 

an enterprise-wide perspective and 

19 Market surveillance includes a broader view of how risks and interconnections tie to nonfinancial businesses and the real economy . 

20 Supervisory reviews should be founded on detailed written standards for cyclical, process-oriented reviews of a regulated entity’s 

preparedness and business resiliency plans to ensure that the regulated entity has a clearly defined path to continue mission critical 

operations during a widespread disruption, such as a natural disaster or the loss of a critical computer system . 
8 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

the authority to facilitate the efficient 

sharing of relevant information during a 

crisis and in managing the operational 

readiness tasks . Prior to crises, agencies 

also designate the staff responsible for 

implementing each aspect of a crisis 

response plan to ensure that relevant staff 

understand how to execute their roles 

and are prepared to do so when the need 

arises . 

•	 Describe Triggering Events . Defining 

what constitutes a crisis that would 

trigger initiation of the crisis response 

plan is important . When triggering events 

activate the crisis plan, the responsible 

crisis leadership officials would then 

undertake affirmative steps to initiate the 

plan . 

•	 Identify Relevant Legal Authorities and 

Tools, and Compile a List of Potential 

Emergency Actions. Prior to a crisis, it is 

important to document a list of available 

legal tools and authorities to assist in crisis 

response . During a crisis, agencies may 

not have the luxury of time and resources 

to identify their relevant legal tools and 

authorities . Therefore, it is beneficial 

during steady state that an agency 

conducts scenario planning and analysis 

that thoroughly vets all legal authorities . 

This list of available legal authorities can 

include potential emergency actions that 

leadership may consider in response to 

various crisis events, as well as regulatory 

authorities available to, among other 

things, provide liquidity to financial 

institutions, support financial market 

infrastructures, facilitate the restructuring 

of troubled institutions, and provide 

regulatory relief . Such preparedness 

efforts also can include considering 

legal authorities that empower agencies 

with multiple options and flexibility to 

award and administer contracts and hire 

and deploy staff in response to a crisis . 

Agencies can also identify any legal 

authorities or tools they do not have but 

may need to manage risk or respond to 

a crisis and take action to seek those 

additional legal authorities or tools . 

•	 Develop Communication Plans and 

Options . A checklist of potential 

internal and external communication 

actions for leadership to consider in 

response to a crisis can be included in 

the plan . Communication both during 

and after the crisis event is integral 

to a crisis response . The checklist can 

include options for: (1) developing and 

implementing a communications strategy 

to promote transparency (i .e ., statements 

by the agency head, Frequently Asked 

Questions, webcasts, interviews, links 

to temporary relief, exemptive orders, 

and staff guidance); (2) creating 

communication templates or leveraging 

existing communication templates; and 

(3) identifying potential communication 

media – for example creating or using 

existing public-facing websites, creating 

call centers, and preparing training 

materials and/or a library of program 

response materials . 
9 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

•	 Prioritize System Capacity, and Cyber 

and Information Security (Aligned 

with Existing Continuity Capabilities)

Crisis readiness plans can also include 

an evaluation of mission critical systems 

and equipment to assess the agency’s 

ability to handle a crisis . An effective 

information security program that meets 

federal standards includes an incident 

response plan that establishes procedures 

for staff to follow during cyber incidents . 

The information security response plan 

documents the triggers, procedures, roles 

and responsibilities, including forming 

an incident assessment group, and 

resources for eradicating and/or limiting 

the expansion of an information security 

incident and minimizing its effects . 

The incident response plan includes an 

incident recovery plan that identifies 

individuals responsible for initiating the 

recovery plan, defines criteria that must 

be met to return compromised services 

and technology to the network, and 

explains how to document the decisions 

and actions taken for future reference . The 

incident response plan also addresses how 

to coordinate communication with internal 

and external stakeholders about response 

and restoration activities . These plans 

and options are aligned with agencies’ 

business continuity plans and encompass 

forecasting budget and staffing resources 

to address crisis response activities 

prospectively before a crisis occurs . 

•	 Provide for Testing, Evaluation, Review, 

Revision, and Training . Crisis readiness 

plans can also include a process to review, 

test, and revise crisis readiness plans on 

a recurring basis .21 Training can ensure 

that agency personnel have the requisite 

knowledge, skills, and abilities to execute 

the crisis management tasks . Training 

can explain the delegations of authority 

and options for potential actions . It 

is important that an agency establish 

feedback mechanisms to assess the 

lessons learned from training, simulation 

exercises, and actions undertaken during 

an actual crisis event to systematically 

incorporate improvements into the 

crisis readiness plans . Periodic reviews 

and readiness plan updates can also 

reflect any changes in the operational 

environment, system resources, leadership 

structure, and the evolution of industry 

standards, laws, and regulations . 

•	 Provide for Reporting . Plans can also 

provide a mechanism to regularly report 

to key decision makers about the agency’s 

crisis readiness . 

Agencies’ Crisis Management 

Crisis planning and crisis management 

work in tandem . Once agency leadership 

determines that a crisis exists, senior agency 

leaders consult and modify, as needed, the 

crisis readiness plans developed during the 

21 For example, agencies can conduct exercises of the crisis readiness plan under different emergency scenarios . These periodic 

exercises, usually occurring at least annually, are followed by an after-action review to capture observations and identify areas for 

improvement . 
Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises 10 

Guidance in Preparing for and Managing Crises 

pre-crisis planning period . These actions 

equip FSOC member agency leaders to 

create the crisis management strategy . 

The crisis management strategy dictates 

the response to a crisis . Key elements 

that contribute to effectively managing a 

crisis include clear leadership response, 

coordination, communication, resource 

assessments, supervisory activities, and 

implementation of response or rescue 

programs . 

•	 Implement Leadership Response. 

Consistent with the roles and 

responsibilities outlined in their crisis 

readiness plans, agencies deploy a 

leadership response in which strategic 

decision-making and coordination occur 

at the senior agency level, and operational 

and tactical authorities remain within 

appropriate business areas to ensure 

efficient management of incidents . The 

senior crisis management team can 

serve to provide strategic leadership, 

set response priorities, inform and/or 

consult with key governance bodies, and 

escalate policy issues as appropriate . 

Meanwhile, a crisis communication team 

may coordinate with crisis leadership and 

support consistent, timely, and effective 

communication with stakeholders . 

•	 Coordinate Among Member Agencies . For 

specific crises, using pre-existing working 

groups or establishing interagency 

working groups and sub-working groups 

fosters the exchange of ideas, and helps to 

facilitate decision-making and determine 

plans for action and communications . 

Working groups can assist leadership by 

providing crisis support and helping to 

facilitate the crisis management process, 

gather status updates, develop situation 

reports, facilitate an understanding of 

business functional and operational 

impacts across the organization, gather 

information from external subject matter 

experts and government authorities, 

and provide situational awareness . 

The working group, or sub-working 

group, also can include a team to 

review available data, assumptions, and 

methodologies in use and recommend a 

consistent analytical framework across 

agencies . Standardizing data is critical 

to the agencies’ collective analysis of the 

economic and financial impacts of the 

crisis, including the effects of the policy 

actions taken in response to the crisis . 

•	 Communicate to Internal and External 

Stakeholders . Publicly communicating 

individual agency’s responses to the 

crisis promotes transparency . Public 

communications provide insight into each 

agency’s efforts and how it is continuing 

to fulfill its mission . Agencies consider 

the options for communicating to agency 

employees, regulated entities, and the 

public . Internally, agencies may consider 

interdivisional instructions for team 

notifications in the event deployments 

become necessary on short notice . 

Internal communication provides updated 

information relevant to employees via 

direct communication and/or a webpage . 

Communications are coordinated with 

crisis leadership, as previously noted . 
11 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Guidance in Preparing for and Managing Crises 

External communication provides for 

statements by agency leaders, interviews, 

guidance, websites, and call centers 

as potential communication channels . 

In addition, interagency guidance and 

interagency statements can be effective 

tools to clarify a supervisory approach and 

convey that message clearly to institutions 

and markets . 

•	 Assess Resources. Managing surge 

staffing by onboarding new employees at 

a pace that aligns with the crisis demands 

on workforce capacities is essential . Senior 

leaders responsible for crisis management 

consider the need to meet both budget 

and staffing increases, commensurate 

with crisis demands . Understanding the 

possible options available in advance can 

help to expedite the potentially largescale hiring and onboarding of new staff 

to address crisis response activities, such 

as administering response programs 

or responding to institutional failures . 

Leaders use flexible hiring and staffing 

approaches, as presented in the crisis 

planning phase . This may also necessitate 

flexible hiring and contracting processes 

during crisis management . Pay, benefit, 

and interim work schedule flexibilities, for 

example, can be useful in expediting the 

hiring process during a crisis . As a part of 

the resource assessment, if changes to the 

workforce occur as a result of the crisis, 

like it did during the COVID-19 pandemic, 

it is important to design training that 

could be quickly transitioned to virtual 

sessions and to provide remote access 

to all employees . Supporting a remote 

workforce required agencies to provide 

technical guidance to assist in securely 

connecting to agency systems . Future 

crises may present different challenges 

requiring agencies to assess additional 

support alternatives for their workforce . 

•	 Supervise Markets and Regulated 

Entities. Coordinating and prioritizing 

supervisory activities on those markets 

and entities that pose the greatest 

risk is critical .22 Adapting supervisory 

approaches, such as: (1) focusing on 

monitoring and outreach to help financial 

institutions and market participants 

understand the challenges and risks of the 

environment, and (2) allowing temporary 

changes to examination activities to 

minimize disruptions . Such changes might 

include granting additional time to resolve 

existing noncritical supervisory findings . 

During a crisis, agencies can communicate 

with other federal and state regulators to 

avoid duplicative efforts and to coordinate 

efforts in executing revised supervisory 

approaches . Notably, large interconnected 

financial institutions often require 

heightened supervisory attention due to 

the greater complexity of their operations 

and the outsized risks that they can pose 

to the U .S . economy . 

22 To accomplish the goal of focusing supervisory activity on those markets and entities that pose the greatest risk, an agency 

conducting prioritized assessments ranks the risks under its jurisdiction and analyzes staff capacity to prioritize how to deploy 

limited resources . Another goal of this approach is to increase the efficiency and effectiveness of information flow collected by 

the agencies related to operational changes and regulatory challenges, and to coordinate with other federal and state regulatory 

agencies . 
Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises 12 

Guidance in Preparing for and Managing Crises 

•	 Deploy Response Programs. Response 

programs typically involve government 

investments, loans, guarantees, or 

repayment modifications, and are 

designed to address the unique 

circumstances of a particular crisis . 

Programs should be transparent, and 

decisions relating to them should be 

documented to ensure that the process 

is clear and understandable, and that 

there is an appropriate level of oversight . 

Having specific, measurable goals for 

federal rescue programs, and aligning 

funding accordingly, is necessary . 

Effective program design clearly identifies 

the metrics by which success will be 

measured and how management will 

monitor and report the agency’s progress 

in meeting these goals . In managing the 

program, agency managers also monitor 

the program’s activities, which ensures 

that funds are used as intended . Regular 

assessments and communication, to 

include the exit path and end date for 

response programs, are also useful . 

•	 Evaluate Lessons Learned. Following a 

crisis and return to steady state, initiating 

after-action reviews to examine the 

cause(s) for any implementation issues, 

analyzing the effectiveness of the agency’s 

crisis management process, identifying 

opportunities for improvement, and acting 

on those opportunities for improvement 

is helpful . It is important that agencies 

coordinate these efforts and collaborate 

to produce post-event analyses and 

reports . Based on the observations in the 

after-action reviews, agency leadership 

should consider initiating improvement 

planning . Improvements should consider 

the applicability to all crisis readiness 

plans, not just to the hazards and crisis 

plans utilized during the preceding crisis . 

Conclusion 

The foregoing guidance is intended to 

assist FSOC and its member agencies in 

coordinating, sharing information, and 

planning for future crises . For FSOC, 

this guidance can be used to collect and 

disseminate crisis readiness information to 

member agencies as well as to assist with 

assessing the risks to the United States’ 

financial stability associated with agencies’ 

crisis readiness preparedness . For member 

agencies, this guidance can be used to assist 

with planning for future crises . The crisis 

preparedness and management practices 

identified and summarized in this guidance 

as well as the crisis preparedness actions 

previously recommended by the IMF and 

GAO can inform FSOC and its member 

agencies and help to preserve the financial 

stability of our nation during future crises . 

On March 23, 2022, FSOC provided a written 

response to this guidance document .23 

FSOC’s response is included as Appendix II . 

23 Prior to issuance of this report, CIGFO and FSOC engaged in pre-decisional discussions to ensure a full understanding of the 

report’s guidance before CIGFO received FSOC’s final management response . 
13 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

APPENDIX I 

APPENDIX I
 

Abbreviations
 

Act/Dodd-Frank Act Dodd-Frank Wall Street Reform and Consumer Protection Act 

COVID-19 Coronavirus Disease 2019 

CFPB Consumer Financial Protection Bureau 

CFTC Commodity Futures Trading Commission 

CIGFO Council of Inspectors General on Financial Oversight 

FDIC Federal Deposit Insurance Corporation 

FHFA Federal Housing Finance Agency 

FIO Federal Insurance Office 

FRB Board of Governors of the Federal Reserve System 

FSOC Financial Stability Oversight Council 

GAO U .S . Government Accountability Office 

HUD U .S . Department of Housing and Urban Development 

IG Inspector General 

IMF International Monetary Fund 

NCUA National Credit Union Administration 

OCC Office of the Comptroller of the Currency 

OFR Office of Financial Research 

OIG Office of Inspector General 

SEC U .S . Securities and Exchange Commission 

SIGTARP Special Inspector General for the Troubled Asset Relief Program 

Treasury Department of the Treasury 
Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises 14 

APPENDIX II 

APPENDIX II
 

Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

APPENDIX III 

APPENDIX III
 

SOURCES USED BY THE CIGFO WORKING GROUP 


TO DEVELOP GUIDANCE
 

COLLABORATION AND PRE-CRISIS PLANNING ACTIVITIES 

Commodity Futures Trading Commission . (2020, October 20) . CFTC and BoE Sign New MOU 

for Supervision of Cross-Border Clearing Organizations [Press Release 8289-20] . https:// 

www .cftc .gov/PressRoom/PressReleases/8289-20 

Commodity Futures Trading Commission . (2019, February 25) . Joint Statement by UK and US 

Authorities on Continuity of Derivatives Trading and Clearing Post-Brexit [Press Release 

7876-19] . https://www .cftc .gov/PressRoom/PressReleases/7876-19 

Commodity Futures Trading Commission . (2020) .

 . (hereinafter “ ”) 

Department of the Treasury Office of Inspector General . (2013) . Safety and Soundness: OCC 

Identification of Emerging Risks https://oig .treasury .gov/sites/oig/files/Audit Reports 

and Testimonies/OIG13037 .pdf 

Federal Deposit Insurance Corporation . (2012) . Effectively Managing FDIC’s Resources – 

Meeting the Challenges of the Financial Crisis, 2008-2011 . (hereinafter “FDIC, Managing 

FDIC’s Resources”) 

Federal Housing Finance Agency . (2019) . AB 2019-01 Business Resiliency Management

https://www .fhfa .gov/SupervisionRegulation/AdvisoryBulletins/Pages/Business-ResiliencyManagement .aspx 

16 
Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

APPENDIX III 

Federal Housing Finance Agency . (2018) . AB 2018-07 Federal Home Loan Bank Liquidity 

Guidance https://www .fhfa .gov/SupervisionRegulation/AdvisoryBulletins/Pages/FederalHome-Loan-Bank-Liquidity-Guidance .aspx 

Federal Housing Finance Agency . (2013) . AB 2013-01 Contingency Planning for HighRisk or High-Volume Counterparties https://www .fhfa .gov/SupervisionRegulation/ 

AdvisoryBulletins/Pages/AB-2013-01-CONTINGENCY-PLANNING-FOR-HIGH-RISK-ORHIGH-VOLUME-COUNTERPARTIES .aspx 

Financial Stability Oversight Council . (2020) . 2020 Annual Report https://home .treasury .gov/ 

system/files/261/FSOC2020AnnualReport .pdf 

Office of the Comptroller of the Currency . (2013) . An International Review of OCC’s 

Supervision of Large and Midsize Institutions https://www .occ .gov/news-issuances/newsreleases/2013/nr-occ-2013-184a .pdf 

Office of the Special Inspector General for the Troubled Asset Relief Program . (2014) . What 

Makes a Bank Systemically Important?, Written Testimony of Christy L . Romero before 

the U .S . Senate Committee on Banking, Housing, and Urban Affairs Subcommittee on 

Financial Institutions and Consumer Protection . https://www .sigtarp .gov/sites/sigtarp/files/ 

Testimony/SIGTARP testimony TBTF and SIFI regulation July 16 2014 .pdf 

CRISIS READINESS PLAN ELEMENTS 

Board of Governors of the Federal Reserve System (2020) . 

(hereinafter “ ”) 

Board of Governors of the Federal Reserve System (2019) . . 

(hereinafter “ ”) 

Board of Governors of the Federal Reserve System (2018) .

supra 

FDIC, Managing FDIC’s Resources, supra 

Federal Deposit Insurance Corporation . (2020) . FDIC Chairman Letter to Representative 

Maxine Waters . (hereinafter “FDIC Chairman Letter”) 

17 
Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

APPENDIX III 

Federal Deposit Insurance Corporation . (2018) . Atlanta Region Critical Event Management Plan. 

Federal Deposit Insurance Corporation Office of Inspector General . (2020) . The FDIC’s 

Readiness for Crises [EVAL-20-004] https://www .fdicoig .gov/sites/default/files/ 

publications/EVAL-20-004 .pdf 

Federal Housing Finance Agency . (2017) . AB 2017-02 Information Security Management

https://www .fhfa .gov/SupervisionRegulation/AdvisoryBulletins/Pages/InformationSecurity-Management .aspx 

Federal Housing Finance Agency . (2018) . AB 2018-06 Liquidity Risk Management https:// 

www .fhfa .gov/SupervisionRegulation/AdvisoryBulletins/Pages/Liquidity-Risk-Management . 

aspx 

National Credit Union Administration . (2020) . 

. (hereinafter “ ”) 

U .S . Securities and Exchange Commission (2020) . . (hereinafter “ 

”) 

U .S . Securities and Exchange Commission (2020) . . 

U .S . Securities and Exchange Commission . (2020) SEC Coronavirus (COVID-19) Response

https://www .sec .gov/sec-coronavirus-covid-19-response (hereinafter “SEC COVID 

Response”) 

U .S . Securities and Exchange Commission . (2018) . U.S. Securities and Exchange Commission 

Strategic Plan Fiscal Years 2018-2022 https://www .sec .gov/files/SEC Strategic Plan 

FY18-FY22 FINAL .pdf 

CRISIS MANAGEMENT 

Consumer Financial Protection Bureau . (2020) .

 . 

FDIC Chairman Letter, supra 

FDIC, Managing FDIC’s Resources, supra 

18 
19 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

APPENDIX III 

Federal Deposit Insurance Corporation . (2017) . Crisis and Response, An FDIC History, 2008­

2013 https://www .fdic .gov/bank/historical/crisis/ 

Federal Deposit Insurance Corporation . (2017) . Draft Debt Ceiling Contingency Planning 

Summaries

Federal Housing Finance Agency . (2020) . (FNM-DER-2020-023) (FRE-DER-2020-027) 

Operational Risks Associated with Coronavirus Disease 2019 (COVID-19)

FRB 2020 , supra 

supra 

NCUA , supra 

Office of the Special Inspector General for the Troubled Asset Relief Program . (2012) . Factors 

Affecting Implementation of the Hardest Hit Fund Program [SIGTARP 12-002] https:// 

www .sigtarp .gov/sites/sigtarp/files/Audit Reports/SIGTARP HHF Audit .pdf 

Office of the Special Inspector General for the Troubled Asset Relief Program . (2009) . Initial 

Report to the Congress https://www .sigtarp .gov/sites/sigtarp/files/Quarterly Reports/ 

SIGTARP Initial Report to the Congress .pdf 

Office of the Special Inspector General for the Troubled Asset Relief Program . (2011) . Legal 

Fees Paid Under the Troubled Asset Relief Program: An Expanded Report [SIGTARP 11­

004] https://www .sigtarp .gov/sites/sigtarp/files/Audit Reports/G%2009%20OFS%20 

Contracting%20Final%2011-004%2009-28-2011 .pdf 

Office of the Special Inspector General for the Troubled Asset Relief Program . (2011) . Quarterly 

Report to Congress https://www .sigtarp .gov/sites/sigtarp/files/Quarterly Reports/ 

October2011 Quarterly Reportto Congress .pdf 

SEC COVID Response, supra 

SEC supra 

U .S . Securities and Exchange Commission (2020) . 

[ ] .
 
APPENDIX IV

APPENDIX IV

CIGFO Working Group

Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

Federal Deposit Insurance Corporation Office of Inspector General, Co-Lead

Jay Lerner, Inspector General, Federal Deposit Insurance Corporation

Terry Gibson Cynthia Hogue Stacey Luck

Rigene Mabry Michael Reed

Special Inspector General for the Troubled Asset Relief Program, Co-Lead

Melissa Bruce, Acting Special Inspector General, TroubledAsset Relief Program

Jenniffer Wilson Marc Geller Jennifer Kim

James Lloyd Gabriele Tonsil

Department of the Treasury Office of Inspector General

Richard Delmar, Deputy Inspector General, Department of the Treasury andActing CIGFO Chair

Deborah Harker Susan Barron Jeffrey Hawkins

Andrew Morgan Tayla Haughton Kajuana Britt

Katherine Draper Sheila Arguello Timothy Cargill

Jackquelynne Foley

Department of Housing and Urban Development, Office of Inspector General

Rae Oliver Davis, Inspector General, Department of Housing and Urban Development

Lisa Sweeney Greg Soames

Board of Governors of the Federal Reserve System and the Consumer Financial Protection Bureau Office of

Inspector General

Mark Bialek, Inspector General, Board of Governors of the Federal Reserve System and Consumer Financial

Protection Bureau

Michael VanHuysen Jason Derr Laura Shakarji

Margaret An Matt Gibbons

Federal Housing Finance Agency Office of Inspector General

Brian Tomney, Inspector General, Federal Housing Finance Agency

Marla Freedman Robert Taylor James Lisle

April Ellison Michael Rivera

National Credit Union Administration Office of Inspector General

James Hagen, Inspector General, National Credit Union Administration

Marvin Stith

U.S. Securities and Exchange Commission Office of Inspector General

Carl Hoecker, Inspector General, U.S. Securities and Exchange Commission

Rebecca Sharek Kelli Brown-Barnes Douglas Carney

Lucia Fuentes Bermudez

U.S. Commodity Futures Trading Commission Office of Inspector General

A. Roy Lavik, Inspector General, U.S. Commodity Futures Trading Commission
21 Council of Inspectors General on Financial Oversight • Guidance in Preparing for and Managing Crises

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