At the NYLIB Annual Regulator Roundtable on January 15, the message from the stage was clear: Expect the unexpected.

Moderated by Steve Bush of Apple Bank, the panel featured leaders from the OCC (Daniel Kelly), FDIC (Mary A. Barry), FRBNY (Adam Kirk), and DFS (Polly Klyce Pennoyer). In their discussion, a point about “unplanned scenarios” sparked my interest and how critical it is to prepare for the unexpected. 

The Silicon Valley Bank (SVB) liquidity crisis was a useful example to point to, and the regulators drove home a key point: operational resilience is non-negotiable. Whether it’s a sudden liquidity crunch, a cyberattack, or a vendor failure, the consensus was that banks must have a playbook for when the unthinkable happens. They framed it not as a matter of if, but when.

The regulators are absolutely right, you need an operational plan. But as I listened to the discussion, I realized there was a critical component missing from the conversation.

Crisis planning is not just about bank operations; it is about communications.

You can have the most robust liquidity contingency plan in the world, but if you cannot communicate that stability to your depositors, investors, and the public in real-time, you won’t maintain control of your own narrative and reputation in the broader market. In the age of social media, rumors travel faster than wire transfers. The gap between an operational glitch and a reputation-destroying run on the bank is often filled by silence.

A key part of managing a crisis event and a successful recovery is a communications strategy that is written before the house is on fire. Too often, communications teams are brought in only after the legal and operational decisions are made. That is too late.

To build this bridge effectively, your crisis manual needs to move beyond operations and include these three communications tactics:

1. Get comms in the room: Your communications leader needs a seat at the table during the initial crisis planning, not just during the crisis itself. They can identify reputational risks that legal or operational teams might miss.
2. Draft “holding statements” now: Don’t wait until the crisis hits to debate wording. Have “fill-in-the-blank” templates ready for different scenarios (e.g., cyber breach, executive departure, systems outage). Speed is your best asset; having a draft ready allows you to respond in minutes, not hours.
3. Arm your frontline: Your branch managers and call center staff are your first line of defense. They need scripts and FAQs immediately. If they don’t have answers, they can’t stop the panic.

Don’t let your crisis playbook sit on a shelf gathering dust. Open it up today and look for the communications module. If it’s missing, or if it hasn’t been updated since 2024, you are vulnerable.

Schedule a tabletop exercise that forces your operations and communications teams to work together. Test your ability to release a statement in under 60 minutes. Because when the unexpected happens, every minute counts, and the only thing worse than a crisis is a crisis you can’t explain.

The regulators are right to push banks to prepare for unplanned scenarios, but true resilience is only achieved when operational readiness and communications readiness are built together. The institutions that emerge strongest will be those that treat communications as a core component of risk management. Because in moments of uncertainty, the market will form a narrative with or without you. The strongest banks are those who prepare for the unexpected.