DATE: March 27, 2020
TO: Chief Executive Officer
FROM: Candace Franks, Bank Commissioner
SUBJECT: Coronavirus Contingency Plans – UPDATE – March 27, 2020
I want to thank you and your institutions for keeping our office updated on your modifications to your bank operations during this pandemic. Although we have heard from most of our banks, I would like to remind you that we do need to be notified if you have a specific branch closure and if you are closing lobby service or making other modifications, it is helpful for us to also receive that information.
In our efforts to provide you with timely and useful assistance, I would like to share additional information regarding the designation of the financial services industry as a Critical Infrastructure Sector. We understand that institutions may have essential staff and employees who are working different schedules in Arkansas or other states where you may have bank locations. In the event that your employees could be impacted by travel curfews or shelter in place mandates, the following guidance may be useful to your institution and your staff.
Treasury recommends firms leverage the guidance from the President, CISA, and Treasury and proactively engage relevant state and local governments to ensure the unrestricted movement of personnel critical to your operations. Since each firm has different requirements, Treasury encourages firms to draft a letter from company leadership explaining that the worker carrying the letter is a critical infrastructure worker who needs to be allowed access to their place of work; Treasury suggests attaching the CISA and Treasury guidance to this letter as provided in these links:
Provide the following documents to employees and contractors so they may have them readily available during travel in restricted areas:
· Paper copy of CISA's "Memorandum on Identification of Essential Critical Infrastructure Workers During COVID-19 Response."
· Paper copy of Treasury Department’s "Statement by Secretary Steven T. Mnuchin on Essential Financial Services Workers.”
· Documentation, on company letterhead, detailing work-related travel and how it aligns with the financial services sector list of essential critical infrastructure workers.
Please do not hesitate to contact us if you have any questions or if you need assistance. We appreciate your service and commitment to the banking industry and your local economies and the State of Arkansas.
Candace A. Franks