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Board Report: 2014-IT-B-018 October 30, 2014

The Board Can Better Coordinate Its Contingency Planning and Continuity of Operations Program

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Our objectives were to evaluate the contingency planning and continuity of operations program (COOP) of the Board of Governors of the Federal Reserve System (Board) to ensure that the Board's contingency planning and COOP provide a coordinated strategy involving plans, procedures, and technical measures that enable the recovery of information systems, operations, and data after a disruption. In addition, we reviewed COOP-related costs in an effort to identify potential cost savings.

To accomplish our objectives, we reviewed federal government guidance and Board procedures for responding to emergency events; we interviewed Board continuity personnel; and we reviewed the Board's enterprise-level COOPs, the division-level COOPs, as well as COOP-related costs. In addition, we visited the Board's alternate work site to evaluate the relocation facility. Additional details on our scope and methodology are discussed in appendix A.


The Board's mission is to provide our nation with a safe, flexible, and stable monetary and financial system. Therefore, it is imperative that the Board maintains the capability to perform its mission with minimal or no interruption during emergencies that could otherwise threaten Board operations, personnel, infrastructure, information systems, or other vital assets.

The Board's COOP is a critical component of the Board's strategy to ensure the continuous operation of critical missions and essential functions in any emergency. It implements emergency management policy, identifies emergency management responsibilities, and specifies procedures for the development and implementation of timely emergency responses.

The Board's COOP serves three interrelated purposes:

  1. to apply accepted best practices of business continuity planning
  2. to comply with federal guidance in National Security Presidential Directive-51/Homeland Security Presidential Directive-20, Federal Executive Branch Continuity of Operations (COOP) (NSPD 51/HSPD-20)
  3. to meet the crisis management objectives set by the Federal Reserve Banks' Conference of Presidents, as listed below:
  • ensure the safety of Federal Reserve staff
  • support the continued functioning of the U.S. financial system
  • maintain, or where necessary restore, the stability of the financial system infrastructure (especially the payment system) and the major institutions that make up the U.S. financial system
  • maintain public confidence in financial markets and institutions

Federal COOP Guidance

The Board's COOP was established as a result of a 1998 presidential decision directive that outlined a federal governmentwide initiative to ensure the performance of Mission-essential Functions under a wide range of circumstances. Mission-essential Functions are the organization- level government functions that must be continued throughout, or resumed rapidly after, a disruption of normal activities. Subsequent to the 1998 presidential decision directive, the following guidance documents have been issued to assist agencies in establishing a COOP:

  • National Security and Homeland Security Presidential Directive (NSPD 51/HSPD-20), National Continuity Policy, May 2007
  • Federal Continuity Directive 1, Federal Executive Branch National Continuity Program and Requirements, February 2008
  • Federal Continuity Directive 1 (FCD-1), Federal Executive Branch National Continuity Program and Requirements, October 20121
  • U.S. Department of Homeland Security, Federal Emergency Management Agency, Continuity Guidance Circular, Continuity Guidance for Non-Federal Governments (States, Territories, Tribal, and Local Government Jurisdictions), July 2013
  • U.S. Department of Homeland Security, Federal Emergency Management Agency, Federal Preparedness Circular 65, Federal Executive Branch Continuity of Operations (COOP), June 2004
  • National Institute of Standards and Technology, Special Publication 800-34, Contingency Planning Guide for Federal Information Systems, May 2010

FCD-1 provides procedural guidance to executive branch agencies on specific steps and actions needed to establish a viable COOP in alignment with NSPD 51/HSPD-20. As a part of this guidance, FCD-1 lays out a step-by-step process for establishing a COOP and provides guidance on the vital elements of a COOP. This guidance includes the process for identifying Mission-essential Functions for an organization and the necessary components of a COOP, which include Test, Training, and Exercise. Although the Board is not required to comply with FCD-1, the Board has voluntarily used it as a framework in the development of its COOP. In addition, the Board identifies compliance with NSPD 51/HSPD-20 as one of the interrelated purposes of its COOP.

The Board's COOP Structure

Numerous stakeholders are responsible for critical functions of the Board's COOP, as follows:  

  • The Management Division's Intelligence Coordination and Continuity Programs unit (ICCP) is primarily responsible for the coordination and administration of the Board's COOP and contingency site. (During our audit, in January 2014 the ICCP was reorganized and renamed the Intelligence and Resiliency Program)
  • The Management Division's Space Planning unit is responsible for managing leasing agreements for the Board's alternate work site and the subtenant agencies that rent contingency space at the alternate work site.
  • The Division of Information Technology (Division of IT) is responsible for the resumption of critical Board systems in a timely manner.
  • All Board divisions are responsible for ensuring that their Mission-essential Functions are identified in their applicable COOPs, that their COOPs facilitate resumption of these functions, and that their personnel are aware of their COOP roles and responsibilities.

The Board's COOP is organized into three sections:

  1. Volume IóBasic Plan
  2. Volume IIóDivision Plans
  3. Volume IIIóSupporting Documents

Volume IóBasic Plan is the umbrella document that establishes, at the enterprise level, the Board's crisis management structure, order of succession, and emergency delegations of authority. Volume IIóDivision Plans supplements Volume I and identifies for each division the critical business functions as well as the personnel, vital information, and other resources needed to perform those functions in emergencies. The supporting documents in Volume III include the Board Relocation Guide, the Employee, Media and Interagency Communications Plan, the Board of Governors Deployment Strategy, and the Pandemic Influenza Annex.

Each division is responsible for developing, approving, and maintaining its own Volume II COOP, and the ICCP developed and maintains Volume I--Basic COOP. The Volume II COOPs are independently owned and developed by each division by using document templates provided by the ICCP. These plans receive final approval and acceptance within each division. Volume II COOPs are critical to the operation of the Board in a continuity event, as they outline the necessary steps and actions each Board division plans to take to maintain critical functions in the event of a disaster in which the Volume I COOP is activated. The ICCP coordinates with the Board divisions in the development of their division-specific Volume II COOPs and combines the Volume II COOPs with the Board's enterprise-level basic Volume I COOP.