Internal Control Questionnaires and Verification Procedures

Contingency Plans

1. Have written contingency plans been developed for partial or complete failure of the systems and/or communication lines between the financial institution and the New York Clearing House, Federal Reserve Bank, data centers, and/or service companies?

2. Are those contingency plans reviewed regularly?

3. Are those plans tested periodically?

4. Has management distributed those plans to all wire transfer personnel?

5. Are sensitive information and equipment adequately secured before evacuation in an emergency, and do security personnel deny further access to the affected areas?

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