Operations

Has Nevada issued any industry-specific operational guidelines for businesses re-opening?

Nevada Governor industry-specific operational guidelines: banking and financial servicesgeneral office environments, and real estate/leasing (5/7/20)

CURRENTLY WE CHARGE-OFF SHARE ACCOUNTS AT 60 DAYS. WITH THE PANDEMIC DO WE HAVE FLEXIBILITY TO EXTEND THE CHARGE-OFF DATE FOR MEMBERS FINANCIALLY IMPACTED?

There is no California state law that speaks to this issue, so we refer to NCUA guidance to federally-insured credit unions.

The Joint Agencies Guidance on Overdraft Protection Programs states, for safety and soundness purposes, “overdraft balances should generally be charged off when considered uncollectible, but no later than 60 days from the date first overdrawn.” (NCUA Letter to Federally Insured CUs 05-CU-03)

While the NCUA has also issued guidance to federally-insured credit unions regarding working with members affected by COVID-19, NCUA Letter to Federally Insured CUs 20-CU-02, and the DBO is also encouraging working with members, we have not seen any guidance suggesting a change in the charge-off timeline. Hopefully, instead the credit union can work with the member to obtain an approved loan to pay the overdraft before 60 days and assist them in these extraordinary circumstances.

You can also ask your DBO Portfolio Manager if they have any recommendations regarding the 60-day charge-off time frame.

CAN THE CREDIT UNION REQUIRE A MEMBER COMING INTO THE OFFICE TO HAVE THEIR TEMPERATURE READ?

While the Equal Employment Opportunity Commission (EEOC) has confirmed an employer’s ability to measure the body temperature of its employees in response to the current COVID-19 pandemic, no similar guidance has been issued with regard to measuring the body temperature of consumers entering a business. At this time, it is not among the current safety protocols recommended by the Centers for Disease Control (CDC) and we are aware of no state or federal agency guidance on this issue.

Requiring a consumer to submit to a temperature check raises potential privacy and discrimination concerns and it is important to weigh the risks and benefits of such a policy. A fever is only one of many potential symptoms of COVID-19 and persons with COVID-19 may not always have a fever. Credit unions are strongly encouraged to discuss any such policy with legal counsel prior to implementation, giving careful consideration to how the process would be administered, by whom, and the procedure for responding to a consumer who objects. First and foremost, however, credit unions should ensure that current social distancing and safety protocols established by federal, state and local authorities are diligently followed at all locations.

IS THERE A PROPER WAY TO CLEAN OUR ATM MACHINES?

Proper cleanliness and disinfecting surfaces that can play host to COVID-19 germs has become even more important during this crisis. Now is an important time to review your cleaning processes for your ATMs and educate branch employees on proper procedures to protect your consumers from the threat of contagious viruses, while also protecting your ATMs from potential damage caused by harmful cleaning supplies.

Watch the following video on How to Clean and Disinfect ATMs and stop the spread of COVID-19 germs.