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OCC Bulletin 2020-23
March 25, 2020
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Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties
The Office of the Comptroller of the Currency (OCC) recognizes the potential for the coronavirus (also referred to as COVID-19) to adversely affect bank1 operations, including the movement of workers responsible for the operations and maintenance of critical infrastructure. On March 19, 2020, the Cybersecurity and Infrastructure Security Agency (CISA) issued a memorandum and initial guidance identifying several categories of workers who conduct a range of operations and services essential to continued critical infrastructure viability. Among the workers that CISA identified are those in the financial services sector. On March 24, 2020, the U.S. Treasury Secretary emphasized in a press release the importance of the financial services sector and reinforced the CISA guidance. This bulletin provides information for essential critical infrastructure workers during the COVID-19 emergency response.
This bulletin applies to all OCC-supervised banks.
Consistent with the March 19, 2020, CISA guidance and the U.S. Department of the Treasury's March 24, 2020, press release, the OCC
In collaboration with other federal agencies and the private sector, CISA developed an initial list of "essential critical infrastructure workers" to inform state and local officials as they work to protect their communities, while ensuring the resiliency and continuity of functions critical to public health, safety, and economic and national security during the COVID-19 response. Among the workers included in CISA's list are those who support the financial services sector.
CISA has identified the following parts of the financial services sector workforce as essential:
The financial services sector relies on third parties and service providers in the information technology sector. CISA has identified the following parts of the information technology sector workforce as essential:
Essential critical infrastructure workers are needed to maintain the services and functions that Americans depend on daily and that need to operate resiliently during the COVID-19 emergency response. Essential workers should follow guidance from the Centers for Disease Control and Prevention as well as state and local officials regarding strategies to limit disease spread.
Banks should consider the following steps for employees and contractors operating in, or moving between, restricted areas to facilitate the continued operation of essential services:
While state and local authorities are responsible for enforcing travel restrictions in place during the COVID-19 response, these steps may reduce the burden on employees needing to travel inside restricted areas to support critical infrastructure.
Please contact Patrick Kelly, Director for Critical Infrastructure Policy, at (202) 649-6550.
Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy
1 The term "banks" refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.