DR Test Scoping Mistakes That Fail FFIEC Review: The Operations-Leader View
Why the Annual DR Test Is an Operations Question, Not a Calendar Item A community bank COO walking into the next disaster recovery test is rarely...
Five Nines Executive Team : Aug 11, 2026, 6:00:00 AM
1 min read
The three terms are sometimes used interchangeably, but they describe distinct functions with different scopes, time horizons, and operational disciplines.
Business continuity is the organizational capability to continue operating during disruption. Disaster recovery is the technical capability to restore systems after disruption. Incident response is the immediate process for handling specific events.
The COO question is not whether the bank has documents labeled BCP, DR, and IR. It is whether the three functions are integrated, exercised, and produce evidence the framework examines.
Business Continuity Planning (BCP) addresses how the bank continues operating during major disruption. Scope: organizational, including people, processes, and technology.
Disaster Recovery (DR) addresses technical restoration of systems and data. Scope: technology infrastructure.
Incident Response (IR) addresses the process for handling specific incidents. Scope: event-specific, often time-compressed.
A real disruption typically exercises all three: incident response triggers business continuity activation, with disaster recovery executing technical restoration in parallel. Banks that exercise the three separately miss the integration the framework expects.
The FFIEC Business Continuity Management booklet describes the integration explicitly. Banks operating the three as separate compartments produce findings; banks integrating them produce defensible programs.
A COO will hear: the three programs are documented, the bank has a BCP, DR plan, and IR procedure; integration is bureaucratic overhead.
False. The framework expects integration. Documents without integration produce findings.
A COO should work through integrated exercise design covering all three.
The three functions integrate or fail together. Documents without integration do not satisfy the framework.
If your bank has not exercised the three together in the last twelve months, that is the conversation worth having with your Tech-Operations partner.
Five Nines Technology Group is a Tech-Operations partner for community banks and credit unions. Translating regulatory frameworks into operating discipline at community bank scale is where our team focuses.
BCP annually, DR annually, IR more frequently with tabletop exercises quarterly.
Both. Separate tests for component validation; integrated exercises for cross-function coordination.
Recent test results. Banks without recent integrated exercise produce findings.
Carriers ask about all three during underwriting.
BCP typically COO; DR typically IT; IR typically qualified individual or security operations.
Through integrated exercises that surface coordination gaps.
DR planning extends to cloud relationships, with coordination requirements documented.
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