COVID-19 & Banking FAQs

ABA’s COVID-19 FAQ contains answers that we have gathered to bankers’ frequently asked questions about the coronavirus pandemic and the impact it’s having on the banking industry, including:

• Branch Operations
  • Cash Handling
  • Reduced Services and Emergency Closures
• Workforce Health & Safety
  • Medical Screening of Staff
  • Americans with Disabilities Act Restrictions
• Regulatory Considerations
• Virus Epidemiology
• Environmental Management
• Procedures

Branch Operations

Cash Handling

• Are there any cash disinfection procedures that banks should follow to ensure the cash they distribute is safe?
• Is the virus transmissible through cash and currency?
• Do you recommend that front-line staff and tellers wear gloves when handling cash, currency, and/or documents from the public wear gloves?

Reduced Services and Emergency Closures

• What are options for reducing the exposure to branch staff and customers? Should we move to drive thru operations and close the lobby?
• Are we required to notify our primary regulator when we temporarily close the branch or reduce services due to exposure or to reduce the risk of exposure to COVID-19?
• Are we required to notify customers if we temporarily close a branch or reduce services due to exposure?
• What type of communication do you recommend to customers regarding the bank’s response efforts?
• Do you have any recommendations around customers coming into branches with masks?

Workforce Health & Safety

Medical Screening of Staff

• What is a recordable illness?

Americans with Disabilities Act Restrictions

• May a bank ask about an employee’s health condition during the coronavirus pandemic?
• May a bank require its employees to adopt infection-control practices, such as regular hand washing or wearing personal protective equipment (e.g., face masks, gloves, or gowns) during the coronavirus pandemic?
• Does the bank have any obligations with respect to maintaining the confidentiality of employee medical information that the bank obtains during the coronavirus pandemic?
• Should we ask an asymptomatic employee to self-quarantine if they have an asymptomatic spouse who was asked to self-quarantine because someone at their company has possibly been exposed? (We can easily see this impacting a great number of employees quickly.)
• How much inforamtion may an employer request from an employee who calls in sick, in order to protect the rest of its workforce during the COVID-19 pandemic?
• When may an ADA-covered employer take the body temperature of employees during the COVID-19 pandemic?
• Does the ADA allow employers to require employees to stay home if they have symptoms of the COVID-19?
• Whem employees return to work, does the ADA allow employers to require doctors' notes certifying their fitness for duty?
• If an employer is hiring, may it screen applicants for symptoms of COVID-19?
• May an employer take an applicant's temperature as part of a post-offer, pre-employment medical exam?
• May an employer delay the start date of an applicant who has COVID-19 or symptoms associated with it?
• May an employer withdraw a job offer when it needs the applicant to start immediately but the individual has COVID-19 or symptoms of it?

Regulatory Considerations

• How are banks handling increases in large cash withdrawals?
• Is there guidance forthcoming from the CSBS?
• What considerations should we give to workers with Federal Reserve access/tokens as we move them to work from home?
• Are banks considered essential services and be exempted from any mandatory closure notices?
• Are onsite exams going to continue? Can we delay an exam that has begun or is scheduled to begin in the next week/month?
• What can banks do to assist small business owners to avoid immediate and potential long-term negative impacts?
• Related Congressional Action

Virus Epidemiology

• What is the difference between the flu and COVID-19? Why the extreme measures for COVID19?
• Can you become re-infected with COVID-19?

Environmental Management

• What type of air filters should be used? High Efficiency Particulate Air Filters (HEPA), etc. and how often should these be changed?
• What is PPE?
• Is the use of UV Lighting an effective method to kill the virus?
• What special considerations are there regarding incoming shipping documents coming into the bank's international department received for collection or under Import Letters of Credit?
• What are the recommended cleaning practices for branches and corporate facilities?
• What if an employee who is working onsite tests positive - what cleaning procedures do I need to follow?

Procedures

• Has anyone created a standard to statement of work for staff and/or your janitorial providers outlining expectations for routine cleaning to avoid exposure? How are the processes different for suspected or confirmed exposure?
• Do you use currently use or are you looking to use vendors who can certify their cleaning processes and products adhere to OSHA* and EPA recommendations?
• Do you have any language, policies and/or directives that you can share?