DATE: March 11, 2020
TO: Chief Executive Officer
FROM: Candace Franks, Bank Commissioner
SUBJECT: Coronavirus Contingency Plans
The State Bank Department has closely followed recent updates and media reports regarding the spread and impact of Coronavirus-COVID-19. We have been in communication with our federal regulatory partners and the Conference of State Bank Supervisors and we have monitored the information released from Governor Hutchinson.
I felt it was important to communicate to each of your institutions regarding our current response and confirm our commitment to assisting our banks. If you have not already done so, we strongly encourage each bank to review and update, as necessary, your existing Business Continuity/Pandemic Plan. We suggest that you begin discussions regarding proposed plans and responsive actions in the event your banking operations, personnel, customer base or facilities are impacted due to the continued spread of Coronavirus.
If your management team concludes that a branch facility or market must be closed in response to staffing shortages, public health concerns, etc., you should promptly communicate the closure(s) via email to Deputy Commissioner Susannah Marshall at email@example.com. Your email should also include:
· Proposed changes in service (branch closing, lobby closing, change in hours of operation, etc.)
· Reason for change in service (staffing shortage, public health concern of community, etc.)
· Estimate for length of time the changes will be in place
We suggest that the bank also provide the same communication to your federal regulator.
As with any unplanned change in operations, we strongly suggest that you maintain communication with both customers and employees. Communications to customers should include:
· Website updates and branch posting notices with changes in hours of operation or limited services at specific locations
· Promote utilization of ATMs, on-line banking applications, mobile banking services and telephonic and electronic mail customer service options
· Provide employees with advanced notice of changes in bank operations and details on how they may best continue to serve the customers and answer questions
With the likely increase in ATM and ITM utilization, we encourage bank management to plan accordingly for needs and requirements and supplies to operate these devices.
In addition, I would like to share the recent communications from the federal agencies regarding institutions’ preparedness and pandemic planning, as well as the agencies’ notice to institutions for supporting consumers during the Coronavirus Crisis.
Lastly, we will continue to monitor all sources of information and communication for both the banking and regulatory industries and make adjustments as warranted on the whole or on a case-by-case basis, if needed. Currently, we have not modified our examination schedule; however, we will consult, in a timely manner, with your institution regarding upcoming examinations or visitations and coordinate our efforts as needed.
If you have any questions, or if we may be of any assistance, please do not hesitate to contact me or any Bank Department staff at 501-324-9019.
Candace A. Franks