On Nov. 17, 2020, Governor Pritzker and the Illinois Department of Public Health (IDPH) announced additional statewide COVID-19 Tier 3 Resurgence Mitigations that will take effect at 12:01 a.m. on Friday, November 20, 2020.
The mitigations are intended to reduce infection rates while preventing issuance of a full “stay at home” order. Guidelines are provided for personal gatherings and meetings, with specific mitigation requirements for industries such as retail, manufacturing, offices, and restaurants.
IDPH will track the positivity rates and hospital capacity over a 14-day period to determine whether mitigations can be relaxed, if additional mitigations are required, or if current mitigations should remain in place.
Are banks still treated as essential businesses?
Yes. The latest guidance does not change the categorization of financial institutions as “essential businesses.”
Is there specific mitigation guidance for financial institutions?
The latest mitigations do not include guidance specific to financial institutions, but as discussed in the following questions, portions of other industries’ guidance will apply to financial institutions.
Do we need to close our lobbies?
No. As of now, banks continue to be considered essential businesses and are not required to close their lobbies. Many institutions have closed lobbies voluntarily, moving to drive-through only service and/or limiting the number of open branches.
Should we shift to all-remote work for employees that are not customer-facing?
Under the “office” category, the guidance says that “all employees who can work remotely should work remotely.”
Are there new capacity restrictions applicable to banks?
Yes. The mitigations state that “customer serving functions should be limited to 25% capacity, aligned with retail mitigations, and maximize work from home wherever possible” on page 4. We also reached out to the state Division of Banking, IDFPR, and confirmed that this 25% capacity limit applies to financial institutions.
Do bank employees count toward the 25% capacity limit?
The mitigation standards do not specifically address whether employees are included. However, the IBA has confirmed that both employees and vendors are not counted towards the capacity limits. It is also noteworthy that the guidance’s capacity limits are based on the total square footage occupied – not just customer-facing areas.
Please let us know if you have additional questions.