By Monica C. Meinert
As the nation turned the calendar page to May, many states began to ease stay-at-home orders and reopen economies that had been brought to an abrupt halt earlier in the spring by the coronavirus pandemic.Like other critical infrastructure businesses, banks remained open throughout the pandemic, with bankers serving as economic first responders: assisting homeowners with finding forbearance options for their mortgages, working round-the-clock to deliver Paycheck Protection Program loans to small business customers and supporting customers as they shifted much of their banking activity to digital channels. For many, this work was conducted on kitchen tables or in makeshift offices setup in laundry rooms and basements. Bankers adapted quickly and overcame obstacles to serve their customers during the pandemic and will continue to do so throughout the nation’s economic recovery.
As of early May, bankers were expecting a near-term return to offices and normal business operations. In an ABA survey of banks conducted around that time, 42 percent expected to be back within 30 days, 31 percent said 60 days, while just 10 percent said they didn’t expect to be back for closer to three months.
Before normal business operations can resume, however, banks will need to answer several tough questions: Will everyone come back at once, or will there be a phased-in return process? Will employees be required to wear face masks to work? How will the bank maintain social distancing between customers in a small lobby? And perhaps most importantly, how will they know which rules and regulations apply to their institution?
A community-focused approach
During a recent ABA webinar, ABA SVP Paul Benda noted that banks should look to local authorities for specific details about when and how to transition back to physical offices. For example, while many areas have been referencing guidance issued by the Centers for Disease Control and Prevention throughout the pandemic, Benda notes that when it comes to actually implementing that guidance, some areas may choose to limit capacity based on square footage or by a percentage of the establishment’s maximum occupancy license, or require markings on the floor to ensure customers maintain proper social distancing.
“That level of tactical, granular guidance is generally going to come from your state and local authorities,” Benda says. However, federal guidelines and regulations—including those issued by the Centers for Disease Control and Prevention, the Occupational Safety and Health Administration and the Equal Employment Opportunity Commission—still apply.
Determining which risk mitigation measures will be necessary for a given market depends significantly on the level of community transmission of the virus in that area. For example, both the CDC and OSHA have based their guidance on community transmission levels. They define three different level of transmission: none to minimal, where there are isolated cases of the coronavirus; minimal to moderate, where there may be widespread or sustained transmission of the virus, with potential for a rapid increase; and substantial, where there is transmission at a large scale that begins to have an effect on healthcare staffing.
“Depending on where you are, you may have to implement different engineering controls, different administrative controls and different PPE requirements,” Benda says. (He advises banks to review OSHA’s 3990 guidance, which provides a comprehensive overview of coronavirus risk mitigation strategies.)
“We really think it’s important for banks to identify the methodology to understand what your local market conditions are and map them to that CDC-defined terminology,” he says. “It’s important to understand where you fall on that spectrum. That can help guide the risk that you’re under and the risk controls you have to implement.” (To help bankers easily track mitigation measures and related guidance, ABA has compiled a free Reopening Matrix tool for members to download.)
Having a documented risk mitigation strategy—along with written policies and procedures that can be scaled as needed—is critical, as certain employers are beginning to face lawsuits from employees who do not feel that adequate protections are in place for them to safely return to work. Benda said he expects to also see a rise in customer lawsuits in the days ahead.
Getting granular
There are several different risk mitigation measures that are being broadly considered by banks nationwide, Benda notes, identifying just a few of the most common:
Face masks. The CDC currently recommends that individuals wear cloth face coverings to help limit the spread of coronavirus. According to the ABA member survey, 58 percent said they plan to require employees and contractors working in branches to wear a face mask, and 51 percent said that they would require back office staff and customers to do so as well.
Face masks present several challenges for banks, from both a physical security and compliance perspective. Benda says he’s heard several different strategies from bankers on how they plan to address masked customers entering branch lobbies. For those who are able, he says, having a door greeter ask incoming customers to momentarily lower their masks so that they can be identified in front of a closed circuit camera might be a good option.
Beyond entering the branch, banks also need to think through their mask policies to ensure that frontline staff will still be able to perform know-your-customer checks. This could be as simple as asking customers to momentarily drop their mask so that the bank employee can verify their identity, which Benda notes “exposes them to a very minimal level of risk.” He adds that some banks are also offering an alternative verification option for customers who aren’t comfortable removing their mask. “Some banks branches are actually implementing their verification procedures that they use when someone calls into a call center.”
Medical checks. Many employers are considering policies requiring workers and/or customers to have their temperatures taken before entering their establishment, and Benda says that legally, there are no problems with doing so. With the EEOC considering COVID-19 a “direct threat” to public health and safety, Benda notes that banks “are allowed to take temperatures, you are allowed to do medical screenings, you are allowed to require a COVID-19 test from your employees. You just have to ensure you protect that information.” That means storing employees’ confidential medical information in a location that is separate from their employee file. When it comes to customers, performing temperature checks are fine, Benda says, but don’t maintain a log of that information.
In the ABA survey, 46 percent said they plan to implement temperature screening measures for employees and contractors at branches, while 20 percent said they would require them for customers and visitors. For institutions implementing such measures, the CDC offers helpful guidance for doing so effectively.
Physical distancing. With physical distancing measures and limited capacity rules likely to be in place for some time, Benda reminds banks to check with their local authorities for any rules that apply to their market—as of May, the CDC was still recommending against gatherings of more than 10 people, but “state and local authorities might be more specific.”To help manage traffic flow and capacity in a bank branch, Benda says one good strategy might be to have customers present themselves at the door, provide a phone number and then wait in their car to be called inside once they can be accommodated.
Airflow. Another important risk mitigation measure involves assessing the HVAC systems in bank branches and back offices to ensure that the airflow setup isn’t helping the transmission of the virus. “Make sure your returns are not behind your tellers, so you’re not sucking air from public spaces,” Benda advises. Extra care should also be taken in bathrooms on bank premises to ensure that exhaust fans are working properly, since studies have shown that the virus may also be transmitted via human stool.
These are a few of many steps banks can take to mitigate the spread of COVID-19 and ensure the safety of employees and customers. However, if a bank employee does contract the coronavirus, they should notify their employer and quarantine themselves for 14 days.
From there, the bank should notify anyone with whom the individual had “close and continuing contact,” according to CDC guidelines. “That means you had to be in contact with that person for a substantial period of time, in a close manner,” Benda explains. The CDC recommends that those individuals also quarantine for 14 days. “There are no real notification requirements for customers,” unless there was sustained contact with the sick individual, Benda adds. Finally, banks should also refrain from disclosing the name of the employee to ensure their privacy is protected pursuant to ADA requirements.
A new normal
However banks choose to transition employees back to the workplace, it’s unclear when—or if—things will ever return to how they were before the crisis began. Nearly two-thirds of ABA members surveyed recently said that they would not require their employees to return to their physical offices, even if their state government lifted capacity restrictions. And a vast majority—92 percent– said they would have measures in place to assist employees who did not feel comfortable returning to the office.
While the COVID-19 pandemic has brought so many uncertainties to everyday life, one thing is certain: that no matter what, America’s banks will always find ways to serve their customers.
