FDIC notes financial service workers deemed ‘essential critical infrastructure’ workers during COVID-19 response

Credit union workers also given 'essential employees' designation

An agency of the Department of Homeland Security (DHS) has provided guidance that identifies financial service sector workers among a list of “critical infrastructure sector” workers who, during the coronavirus crisis, are needed to ensure continuity of functions “critical to public health and safety, as well as economic and national security,” the federal insurer of bank deposits said in a Financial Institution Letter (FIL) Thursday.

“The guidance is intended to support state, local, and industry partners in identifying the critical infrastructure sectors and the essential workers needed to maintain the services and functions to operate without interruption,” the Federal Deposit Insurance Corp. (FDIC) said in the letter.

The list was produced by the DHS Critical Infrastructure Security Agency (CISA) in collaboration with other federal agencies and the private sector. It’s intended to assist state and local communities in prioritizing activities related to continuity of operations and incident response, “including the appropriate movement of critical infrastructure workers within and between jurisdictions,” the FDIC explained.

The CISA itself noted that this guidance is advisory in nature and that it is not “a federal directive or standard in and of itself.” That said, the agency’s list treats as “essential critical infrastructure” workers those workers who:

  • are needed to process and maintain systems for processing financial transactions and services (e.g., payment, clearing, and settlement; wholesale funding; insurance services; and capital markets activities);
  • are needed to provide consumer access to banking and lending services, including ATMs, and to move currency and payments (e.g., armored cash carriers); and
  • support financial operations, such as those staffing data and security operations centers

The FDIC also notes that certain documents may help ensure workers continued access to their workplace during the response to the coronavirus crisis. “A letter from company leadership explaining that the identified worker carrying the letter is a critical infrastructure worker who needs to be allowed access to their place of work, and the attached documents may assist essential critical infrastructure workers needing to travel inside restricted areas in order to support critical infrastructure,” the agency said.

This guidance ties back to President Donald Trump’s “updated coronavirus guidance” March 16 that advised that critical infrastructure workers “have a special responsibility to maintain your normal work schedule” and which is underscored in a statement March 24 by Treasury Secretary Stephen Mnuchin.

Identification of Essential Critical Infrastructure Workers During the COVID-19 Response Efforts (FIL-25-2020)