November 6th, 2020 | Joy Henry, General Manager, Sterling’s Financial and Business Services Group

Financial Services Return to Work: Prioritizing Roles and Establishing Protocols for Health and Safety

In recent years, there has been a trend across many industries towards remote work, led by the technology industry. However, the financial services industry has been slow to follow. Because of regulatory compliance requirements and the need for access to on-premise infrastructure, it has been difficult for those in the industry to consider working away from the physical office. As an example, even though electronic trading has grown on Wall Street, the New York Stock Exchange (NYSE) adapted, but has continued to maintain the physical trading floor.

During the COVID-19 pandemic however, in a historical move, NYSE closed the trading floor while electronic trading continued. Many in the financial services industry, including banks, insurance companies, stock brokerages, and fund managers shuttered their offices temporarily and moved operations online. Albeit difficult, resource heavy to support, and limited in certain functions, the financial services industry did not have much of an alternative. Now, as the world begins returning to in-office work, financial services organizations need to determine which roles to prioritize back in the office as well as the health testing and safety protocols that need to be established to open offices safely.

Financial Services Prioritizing Return to Workplace

As the world is now navigating phased re-opening and return to work, they are confronted with a new set of rules for the health and safety of those needing to work in office spaces. Offices are opening with less capacity, and many employees continue to work remotely during the first reopening phases. Businesses need to make decisions on how to prioritize roles that need to come back to physical workspaces to minimize effort and potential risk.

Financial services have an added responsibility in getting their offices up and running, with certain roles prioritized to come back on-site quickly. Interest rates are at historical lows; both the Federal Reserve and European Central Bank (ECB) cut rates to zero, limiting the abilities of other central banks. Many regions are already in recession. In order to kickstart economies, financial services must play a central role. Banks act as stabilizers for their employees, customers and economies, and provide the cash and deposit services, credit extension, payment facilitation, and market making.

Many of the essential roles within the financial services industry that facilitate these services are customer-facing, require on-premise infrastructure, or must adhere to compliance requirements that make it difficult or nearly impossible to support remotely. Financial organizations need to carefully consider the impact of continuing services remotely, particularly as it relates to data security, fraud, cybersecurity, and privacy, especially when safeguarding personally identifiable information (PII). As an example, trading is central to market functioning, but cannot be easily executed remotely because of technology and compliance requirements. While banks have taken significant actions to trade remotely over this period, these are difficult and expensive to support long term.

Financial organization need to consider role responsibilities and requirements and balance them with programs they are putting into place to facilitate a safe and healthy work environment.

Health and Safety

As businesses reopen their doors, they need to follow government health mandates, provide appropriate equipment and establish protocols around health and safety. Importantly, these and other measures need to be implemented to ensure employees and customers feel safe both physically and emotionally.

COVID-19 Testing Programs

To ensure a healthy and safe environment, businesses are planning and executing COVID-19 health and safety programs. The Center for Disease Control and Prevention (CDC) provides and updates guidance regularly, including conducting daily health checks, conducting a hazard assessment of the workplace, encouraging employees to wear face masks when appropriate, implementing policies and practices for social distancing, and improving ventilation systems. The US Equal Employment Opportunity Commission (EEOC) has provided guidance as well on what testing may be performed and what information may be stored by an employer. Employers may take employee temperatures and may survey employees on symptoms, provided that such programs are compliant with applicable anti-discrimination laws. While employers may administer tests to determine whether an employee currently has the COVID-19 virus, under the current guidance they may not require antibody testing, or use antibody testing to make decisions about returning to work.

The Americans with Disabilities Act (ADA) requires all medical information about an employee be stored separate from the employee’s personal file. All information related to COVID-19, including an employee’s or employer’s statement or note that an employee was infected with the virus, description of symptoms, temperature or COVID-19 test results must be stored in an employee’s medical file, separate from other employee files to ensure confidentiality.

Taking the guidelines into account, many financial services organizations are developing plans that include surveying employees about their health and travel history, administering regular COVID-19 testing, temperature taking, and quarantining when information indicates infection.

Many financial services organizations, including Goldman Sachs, Bloomberg, Capital One, and Discover have on-site occupational health clinics, enabling them to implement these programs relatively quickly. We recommend partnering with a third party that has existing relationships with organizations at the forefront of occupational health testing, to create order and process while developing these programs quickly and efficiently. Ensure the partner is focused on the quality of tests, has relationships with reliable laboratories, and uses safe and convenient nationwide collection sites to support your organization. An additional benefit of an outside party is the confidentiality and controls that are put in place external from the business for storing and leveraging sensitive employee medical information.

Every organization has different testing requirements including initial COVID-19 return to work testing, and regular re-testing of employee populations. Those requirements will continue to change as the CDC and EEOC update guidelines and businesses adapt to the evolving coronavirus pandemic. Ensure the partner you choose supports multiple testing options, is available to respond with the tests and support needed, can anticipate the quickly changing landscape and requirements, and supports offerings that are flexible and scalable, ensuring they are providing the most reliable tests as they become available.

Risk Assessment

Once banks and others in the financial services industry prioritize those roles returning to brick-and-mortar locations and develop new health and safety programs, they need to establish screening requirements for hiring, rehiring, and returning to work. Financial institutions are responsible for protecting their customers from dishonest, reckless, or fraudulent behavior. FINRA recommends regularly screening candidates and employees appropriately for indicative events that either disqualify them from performing securities-related functions or require establishing supervisory controls for safety and security. It’s important that background screening and rescreening programs include credit, liens, judgments, and bankruptcies. These reports flag risk indicators and enable organizations to leverage data to make better hiring and rehiring decisions.

A resilient return to workplace plan will be flexible enough to navigate the uncertainty of this constantly shifting COVID-19 pandemic. Once organizations create their return to workplace plan by prioritizing roles, developing health testing and safety protocols, and performing risk assessment screening – while considering best practices and government issued guidelines – they can feel confident that they have taken the right steps to protect their employees, customers, partners, reputations, and brands.


Joy Henry is the General Manager of Sterling’s Financial and Business Services group. Joy joined Sterling in 2013 as Vice President of Account Management, and helped launch the company’s first vertical teams. She also previously held the role of Senior Vice President of Regulated Industries, where she worked with Sterling’s most regulated customers in healthcare, financial services, and transportation. Prior to Joy spent nearly 15 years at Dow Jones/Factiva serving in various roles across the organization. Joy holds a BS degree in Marketing from the University of Scranton.

This publication is for informational purposes only and nothing contained in it should be construed as legal advice. We expressly disclaim any warranty or responsibility for damages arising out this information. We encourage you to consult with legal counsel regarding your specific needs. We do not undertake any duty to update previously posted materials.