With factors ranging from staff safety, legal and liability concerns, to human resource policies, local government directives and logistical issues around maintaining social distancing within the office, SIFMA, in consultation with its members, has outlined common considerations as securities firms contemplate a return to normal operations.
“Considerations for Return to Office” is based on the results of a survey of 60 firms and financial utilities, representing a broad cross section of the financial services industry, including GSIBs, regional brokerages, retail and institutional firms, asset managers and service providers.
“Every firm will have to tailor their own plan, but what we tried to do is have the firms collectively come together to find out what everyone is thinking about and how they’re going to do this when they feel it’s time to start bringing people back in,” explained SIFMA President and CEO Kenneth Bentsen, Jr. in a May 27 interview with BloombergTV’s David Westin.
“There are a whole host of issues around regulation and compliance, but we’ve been engaged with our regulators on if we have a ‘new normal,’ how do we make sure that we fit within the rule set or the rule set fits within that new business model,” Bentsen observed.
Among the range of topics addressed in the paper include:
- employee return criteria and return to office threshold;
- second wave planning;
- employee safety and risk management implementation;
- employee testing, certifications and tracking;
- office configuration and hygiene;
- work from home technology; and
- legal, compliance, communications and human resources.
SIFMA advises that firms using the considerations should make individual decisions regarding their strategy and tactics for the new operating environment. “As this situation evolves and as firms start to execute their plans, other considerations will undoubtedly arise as firms better understand how returning staff to the office will work in practice and evaluate the resulting lessons learned,” the paper emphasizes.
Planning, Implementation and Communication
In the area of planning and governance, SIFMA suggests that financial firms should consider “forming internal cross-functional stakeholder working groups” to plan the execution of returning to office. Firms also should communicate plans with their primary regulators and look to federal, state and local government and health care authorities for guidance before executing any return-to-office plans.
Additionally, firms should develop specific policies and procedures around a return to office and update employee handbooks to reflect changes in the new operating environment, the paper advises.
As for implementation, return-to-office plans may involve phased return strategies, such as rotating small percentages of critical staff for the first few weeks between office and home, focused on key functions. Firms may also want to maintain a core set of critical staff in a work-from-home environment to “guarantee critical functions will continue in the event of another disruption,” the paper advises.
To mitigate potential risk to employees, strategies may include monitoring and managing employee health, including preventive monitoring, such as employee self-attestations and temperature checks prior to leaving home, temperature scans at building entrances, and mandating that employees stay home if they are feeling sick, SIFMA further suggests. And in what should go without saying, firms should also apply policies consistently across employees and in a non-discriminatory manner.
Additional recommendations include that firms should develop communications protocols that support their return-to-office plans which are designed to inform a range of stakeholders, from staff to clients. “Communication should be frequent and transparent so that staff are aware of protocols and steps being taken to keep spaces safe and employees healthy,” the paper further emphasizes.
