Jackson Kelly PLLC

Bank Notes

CDC COVID-19 Guidance for Banks - Simplifying the Process for Lowering Risk

July 24, 2020

By: Mark A. Mangano

It has been over four months since the COVID-19 pandemic emergency was declared. During that time, banks have been tasked with crafting solutions to address COVID-19 safety issues while assessing requirements of state executive orders, guidance from the Occupational Safety and Health Administration (OSHA), recommendations from state health agencies, and guidance from the Centers for Disease Control and Prevention (CDC). The official government orders, guidance, and recommendations have evolved as understanding of the virus has evolved. Monitoring, evaluating, and interpreting these sources to implement best practices appropriate to the banking environment has been challenging at best.

The COVID-19 pandemic has not abated. In many areas infection rates remain high. For bankers, the COVID-19 risks raise concerns for the health and safety of bank employees and customers, the ability to maintain staff essential to safely operate the bank, and the liability risks related to individuals claiming that they contracted the virus from contact with the bank. In managing these risks, it would be helpful to be able to refer to a single source for information on issues specific to the banking environment. The CDC has tried to assist banks and their employees in more easily understanding their respective roles in limiting the risks of the pandemic while providing critical services to their customers and communities.

The CDC has issued two guidance statements related specifically to banks: COVID-19 Employer Information for Banks (Employer Information)1 and What Bank Employees Need to Know about COVID-19 (Employee Information)2. The statements are updated as recommendations change. The statements were most recently updated on June 28, 2020. The guidance statements do not address state specific directives or orders, but they begin to collect the relevant federal resources in one place.

COVID-19 Employer Information for Banks

The Employer Information addresses four topics: how the virus spreads, how to protect your staff and others, staff education, and creating a healthy place of business. Under each topic, the Employer Information provides general information, recommendations, and references to other guidance from the CDC and OSHA.

Protecting staff and others

Under the topic “How You Can Protect Your Staff and Others and Slow the Spread”, the statement addresses three steps:

  1. Create a COVID-19 workplace health and safety plan;
  2. Identify where and how employees might be exposed to COVID-19;
  3. Develop hazard controls using the hierarchy of controls3 to prevent infection among employees.

Educate employees and supervisors

Under the topic “Educate Employees and Supervisors About the Steps They Can Take to Protect Themselves at Work and Home” the statement includes suggestions on communication and training related to symptoms of infection, staying home when ill, social distancing, hand-washing, proper use and care of face coverings, and how to reduce transmission at work, at home, and in community. The statement also recommends signage to reinforce training.

The Employer Information also provides links to numerous resources from the CDC, OSHA and the National Institute for Occupational Safety and Health.

What Bank Employees Need to Know about COVID-19

The Employee Information statement provides basic information regarding how COVID-19 spreads and how employees can encounter the virus on the job. The statement also provides detailed recommendations regarding:

  • Staying home if an employee has symptoms;
  • Staying at least 6 feet away from customers and coworkers;
  • Using a cloth face covering as appropriate;
  • Cleaning and disinfecting frequently touched surfaces;
  • Washing hands;
  • Avoiding touching eyes, nose, or mouth; and 
  • Covering coughs and sneezes.

The statement provides numerous links to help employees better understand how to comply with recommended precautions.


There is no perfect way to prevent COVID-19 infection from impacting a bank’s employees or customers. Compliance with CDC guidance does not guaranty safety or that individuals will not seek to hold the bank accountable for infections traced back to contact with a bank location. CDC does represent authoritative guidance on the level of care that banks should take to manage the health risks of COVID-19.

There are three steps a bank should take to gain maximum value from the Employer Information statement:

  1. Carefully review the Employer Information statement and referenced resources;
  2. Compare the bank’s current COVID-19 health risk response to the CDC guidance; and
  3. Document the bank’s health risk response and how it addresses the significant recommendations of the CDC guidance.

Given the increasing infection rates across the country, it is more a question of when a bank customer or employee will become infected rather than if they will become infected. Reviewing, addressing, and documenting implementation of the CDC guidance will have the dual benefits of decreasing the risk of COVID-19 infection and reducing the risk that the bank will bear liability for infections. 



1  https://www.cdc.gov/coronavirus/2019-ncov/community/organizations/bank-employers.html
2  https://www.cdc.gov/coronavirus/2019-ncov/community/organizations/bank-employees.html
3  The hierarchy of controls refers to a hierarchy of responses to occupational hazards the that ranges from most effective to least effective controls.


© 2021 Jackson Kelly PLLC. All Rights Reserved.