Function by function
Each of the fourteen functions of this industry was reached in each quarter by instruments with exhibit identifiers, and each was modified by order in a way the statute names: closure, capacity, hours, screening, distancing, face coverings and the other infection-prevention and exposure-control requirements, appointment-only or remote operation, the termination of a collection process, the compulsion of a forbearance, the prohibition of a cancellation, or the removal of staff by quarantine. The determination for each function follows from Tri-State's definition and the orders' own terms.
BR, branches and lobbies
In the second quarter of 2020 the stay-at-home orders of every State permitted the branch only as an essential service under distancing and telework conditions (Ex. IL-005; Ex. NJ-004; Ex. NJ-011; Ex. NY-003; Ex. PA-002; Ex. KY-010; Ex. MN-010; Ex. DE-006; Ex. OR-007; Ex. WA-016; Ex. CA-002; Ex. TX-008), Vermont confined it to ATM and drive-through operation (Ex. VT-010), New Jersey capped it at 50 percent under face-covering and cleaning requirements from April 8 (Ex. NJ-011) and San Diego County placed its employees under a face-covering requirement from April 27, one of the airborne-transmission controls the County imposed on essential businesses (Ex. MET-SAN-005). In the third and fourth quarters of 2020 and the first quarter of 2021 the reopening orders' caps and the face-covering mandates of every State that issued one, airborne-transmission controls on every indoor business, governed every lobby (Ex. TX-022; Ex. TX-025; Ex. PA-015; Ex. PA-020; Ex. OH-030; Ex. IN-035; Ex. OR-025; Ex. KS-030; Ex. KY-022; Ex. NC-022; Ex. MA-023; Ex. CT-021; Ex. CT-079; Ex. IL-013; Ex. MN-027), and the winter orders re-capped them (Ex. IL-031; Ex. WA-047; Ex. NV-030; Ex. CO-035; Ex. CO-037). In the second quarter of 2021 the last caps and face-covering requirements, airborne-transmission controls on every indoor business, ran to their expiry (Ex. PA-040; Ex. NY-054; Ex. MA-048; Ex. IL-037; Ex. CA-029; Ex. OR-043; Ex. WA-064). In the third quarter of 2021 the indoor face-covering reinstatements of Hawaii, the District, Nevada, Louisiana, Oregon, New Mexico, Washington and Illinois, the unvaccinated-person mandates of California and Connecticut and the orders of more than thirty metropolitan jurisdictions bound every lobby (Ex. HI-023; Ex. DC-057; Ex. NV-041; Ex. LA-036; Ex. OR-048; Ex. NM-067; Ex. WA-078; Ex. WA-080; Ex. IL-042; Ex. IL-043; Ex. IL-044; Ex. CA-036; Ex. CT-050; Ex. MET-LA-018; Ex. MET-SFO-010; Ex. MET-SAC-015; Ex. MET-STL-021; Ex. MET-KC-002; Ex. MET-MSY-027; Ex. MET-BAL-017; Ex. MET-PHL-019; Ex. MET-CLT-025; Ex. MET-CHI-026; Ex. MET-BOS-013; Ex. MET-CMH-050; Ex. MET-DFW-028), Oregon's rule naming "banks" and Washington's prohibiting the admission of persons without face coverings.
The modification
The orders compelled closure to walk-in traffic; confinement to drive-through and ATM; capacity caps of 25 and 50 percent; screening, distancing and face coverings for every teller and customer, the workplace infection-prevention and exposure-control requirements of the reopening and Delta-wave orders; refusal of admission to persons without face coverings; and the operator's liability for each.
The operation of the branch and lobby function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the stay-at-home, capacity, face-covering and telework orders named above.
AT, ATM, drive-up and cash logistics
The essential-infrastructure designations of Treasury and CISA and the State stay-at-home orders permitted cash logistics, ATM servicing and drive-up lanes as exceptions to the confinement of everyone else (Ex. SEC-13-001; Ex. SEC-13-033; Ex. FED-394; Ex. AGY-FED-FINANCIAL-012; OCC Bulletin 2020-23, Ex. AGY-FED-FINANCIAL-013, as context); Vermont made them the sole permitted mode of banking (Ex. VT-010); the face-covering and distancing orders of 2020 and 2021 governed the lane, the vault and the servicing visit (Ex. NJ-011; Ex. PA-008; Ex. OR-048; Ex. WA-080); and the Federal Reserve's deletion of the six-transfer limit on April 24, 2020 recorded the regulator's own finding that confined depositors could not reach the branch (Ex. SEC-13-007).153
The modification
The orders compelled operation as the sole or principal channel under distancing and face-covering requirements, and the regulator reconfigured the deposit rules because of the confinement orders.
The operation of the ATM, drive-up and cash-logistics function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the stay-at-home orders and essential-infrastructure conditions of 2020, the face-covering and distancing orders that governed the lane, the vault and the servicing visit in every quarter to their expiry in the spring of 2021, and the indoor face-covering reinstatements of the third quarter of 2021 named above; each compelled modification is a partial suspension on Tri-State's definition and the Notice's own Q&A-17.
CC, contact centers
The telework mandates of New York, New Jersey, Pennsylvania, California, Illinois, Michigan, Minnesota, Oregon, Washington, Vermont, Kentucky and Delaware emptied the floors in the second quarter of 2020 (Ex. NY-003; Ex. NJ-004; Ex. PA-002; Ex. CA-002; Ex. IL-005; Ex. MI-011; Ex. MN-010; Ex. OR-007; Ex. WA-016; Ex. VT-009; Ex. KY-010; Ex. DE-006); the reopening orders capped them (Ex. KY-017; Ex. KY-019; Ex. CT-021; Ex. CT-079; Ex. MA-023; Ex. TX-022); the winter orders emptied them again in eleven jurisdictions (Ex. NY-008; Ex. IL-031; Ex. MN-032; Ex. WA-047; Ex. PA-022; Ex. SEC-09-023; Ex. IA-029; Ex. CA-020; Ex. AGY-ST-LABOR-WORKPLACE-049; Ex. NV-030; Ex. CO-035; Ex. CO-037); the workplace standards of Virginia, California, Oregon, Washington and Michigan bound every seat that remained (Ex. ECO-B-045; Ex. VA-037; Ex. AGY-ST-LABOR-WORKPLACE-001; Ex. AGY-ST-LABOR-WORKPLACE-002; Ex. ECO-B-044; Ex. AGY-ST-LABOR-WORKPLACE-050; Ex. AGY-ST-LABOR-WORKPLACE-053; Ex. AGY-ST-LABOR-WORKPLACE-062; Ex. OR-032; Ex. OR-041); and in the third quarter of 2021 New York's Subpart 66-3 and HERO Act plans, New Jersey's Executive Orders 242 and 243 and the indoor face-covering reinstatements governed the floor (Ex. NY-133; Ex. ECO-B-120; Ex. AGY-ST-LABOR-WORKPLACE-011; Ex. NJ-050; Ex. SEC-09-038; Ex. OR-048; Ex. WA-078; Ex. IL-042; Ex. IL-043). The Bureau's Bulletin 2021-02 put every servicer's contact-center staffing under supervisory scrutiny from April 1, 2021 (Ex. SEC-13-010).
The modification
The orders compelled remote operation by mandate, occupancy caps, screening, distancing and face coverings, and exposure-prevention plans, and placed staffing under the regulator's scrutiny.
The operation of the contact-center function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the telework mandates, the winter orders, the workplace standards and the face-covering reinstatements named above.
CL, consumer and auto lending
Dealerships closed as non-essential retail in the spring of 2020 and were confined to on-line sales in Honolulu (Ex. NY-003; Ex. NJ-004; Ex. PA-002; Ex. MI-011; Ex. IL-005; Ex. MA-008; Ex. WA-016; Ex. MET-HNL-006); motor-vehicle offices closed to the public in at least twenty States and the District in March 2020 under the States' closure orders and ran by appointment into 2021 (Ex. AGY-ST-DMV-SOS-RECORDERS-097; Ex. NV-006; Ex. IL-053; Ex. PA-102; Ex. DE-072; Ex. CT-003; Ex. MI-012; Ex. DC-082; Ex. MD-098; Ex. TX-069; Ex. MET-SDF-008; Ex. MET-SDF-036; the agencies' closure notices, Ex. AGY-ST-DMV-SOS-RECORDERS-019, Ex. AGY-ST-DMV-SOS-RECORDERS-018, Ex. AGY-ST-DMV-SOS-RECORDERS-002, Ex. AGY-ST-DMV-SOS-RECORDERS-007 and Ex. AGY-ST-DMV-SOS-RECORDERS-099, as context); Illinois suspended every vehicle repossession from March 27, 2020 and garnishments to June 25, 2021 (Ex. IL-008; Ex. IL-010); Maryland barred self-help auto repossession from April 3, 2020 to August 15, 2021 (Ex. SEC-13-071; Ex. MD-031); Alaska barred motor-vehicle repossessions to June 30, 2020 (Ex. AK-002); Washington barred garnishments from April 14, 2020 (Ex. WA-028) and New Mexico's Supreme Court stayed consumer-debt garnishment and execution writs to August 2, 2021; Nebraska and South Dakota waived title and registration deadlines because county offices were closed (Ex. AGY-ST-DMV-SOS-RECORDERS-006; Ex. SD-018); and the Bureau's Regulation F bound every collector from May 3, 2021 (Ex. SEC-13-008).154
The modification
The orders halted origination with the dealer and the motor-vehicle office, delayed perfection by appointment regimes and waived deadlines, and terminated collection by repossession and garnishment in the States and periods named.
The operation of the consumer and auto lending function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the dealer closures, the motor-vehicle office closures and appointment regimes, the repossession and garnishment bars and the Bureau's rule named above.
ML, mortgage lending
Showings were barred in Nevada, Vermont, Michigan and Washington (Ex. VT-014; Ex. MI-017; Ex. NV-014; Ex. NV-017; Ex. WA-109); real estate was confined to appraisal and title services in Mecklenburg County (Ex. MET-CLT-018); the federal agencies deferred appraisals for 120 days and the Enterprises accepted exterior-only and desktop reports to May 31, 2021 (Ex. AGY-FED-FINANCIAL-017; Ex. AGY-FED-FINANCIAL-040; Ex. AGY-FED-FINANCIAL-098; the interagency statement and the FHFA announcement, Ex. AGY-FED-FINANCIAL-016 and Ex. AGY-FED-FINANCIAL-100, as context); recorders closed or limited their counters (Ex. AGY-ST-DMV-SOS-RECORDERS-054; Ex. AGY-ST-DMV-SOS-RECORDERS-057; Ex. MET-PHL-086; Ex. MET-SDF-021; Ex. MET-SDF-022; Ex. MET-MSY-078; the Dallas County Clerk's, Cook County Clerk's and Mecklenburg Register's closure notices, Ex. AGY-ST-DMV-SOS-RECORDERS-114, Ex. AGY-ST-DMV-SOS-RECORDERS-052 and Ex. AGY-ST-DMV-SOS-RECORDERS-075, as context); twenty-five States rewrote the law of notarial acts, eight into the third quarter of 2021 (Ex. AGY-ST-DMV-SOS-RECORDERS-036; Ex. AGY-ST-DMV-SOS-RECORDERS-038; Ex. AGY-ST-DMV-SOS-RECORDERS-039; Ex. AGY-ST-DMV-SOS-RECORDERS-040; Ex. AGY-ST-DMV-SOS-RECORDERS-041; Ex. AGY-ST-DMV-SOS-RECORDERS-042; Ex. AGY-ST-DMV-SOS-RECORDERS-043; Ex. AGY-ST-DMV-SOS-RECORDERS-044; Ex. AGY-ST-DMV-SOS-RECORDERS-046; Ex. AGY-ST-DMV-SOS-RECORDERS-050; Ex. AGY-ST-DMV-SOS-RECORDERS-113; Ex. MA-053; Ex. GA-042); the Paycheck Protection Program's April 2020 rule diverted lending staff (Ex. FED-341); and the forbearance and reporting mandates changed the sale and servicing of every originated loan (Ex. FED-340; Ex. SEC-13-017; Ex. NY-013; Ex. NY-100; Ex. MA-052).155
The modification
The orders barred showings, deferred or converted appraisals, moved closings to remote notarization or delayed them at closed counters, confined recordings to mail or e-recording, and redeployed origination staff to a federal program.
The operation of the mortgage-lending function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the showing bans, the appraisal deferrals, the recorder and notarial regimes and the program rules named above.
BL, business lending and deposits
The commercial borrowers of this industry were closed, capped and re-closed by the orders catalogued on the other industry pages of this site; the Paycheck Protection Program's rules governed every lender from April 3, 2020 (Ex. FED-341; Ex. AGY-FED-FINANCIAL-086; Ex. AGY-FED-FINANCIAL-087; Ex. AGY-FED-FINANCIAL-088; Ex. AGY-FED-FINANCIAL-026; NCUA letter, Ex. AGY-FED-FINANCIAL-037, as context); the commercial-eviction and utility bars of Arizona, Oregon, New Jersey, New York, San Francisco, Los Angeles, San Diego and the District reached the collateral and tenants of commercial loans (Ex. AZ-011; Ex. OR-010; Ex. NJ-061; Ex. NY-020; Ex. MET-SFO-055; Ex. MET-LA-030; Ex. MET-SAN-038); the District's Act 23-286 compelled 90-day deferments; the interagency statements on loan modifications (guidance) implemented CARES Act § 4013 (Ex. FED-342; Ex. AGY-FED-FINANCIAL-015, as context); and the Temporary Asset Thresholds rule and the NCUA's relief changed the regulatory treatment of the balance sheet through 2021 (Ex. AGY-FED-FINANCIAL-027; Ex. AGY-FED-FINANCIAL-048).156
The modification
The orders left the function underwriting and collecting against closed businesses, converted the lending function to a federal program's terms, and barred the enforcement of the commercial leases and utilities that secure or accompany the loans.
The operation of the business-lending function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the orders on the industry's commercial borrowers, the program rules and the commercial-eviction and utility bars named above.
SV, servicing, forbearance, collections and the moratoria
The instruments that reached the function are these: CARES Act §§ 4021 through 4024 from March 27, 2020 (Ex. FED-340; Ex. SEC-13-017); the federal housing agencies' moratoria from March 18, 2020, extended eight times to July 31, 2021, and the foreclosure-related eviction moratoria to September 30, 2021 (Ex. FED-346; Ex. FED-356; Ex. FED-368; Ex. FED-348; Ex. FED-349; Ex. FED-350; Ex. FED-353; Ex. FED-354; Ex. FED-360; Ex. FED-361; Ex. FED-362; Ex. FED-363; Ex. FED-364; Ex. FED-370; Ex. FED-371; Ex. FED-372; Ex. FED-373; Ex. FED-374; Ex. FED-375; Ex. FED-376; Ex. FED-378; Ex. FED-379; Ex. SEC-13-012; Ex. SEC-13-014); the CDC's orders from September 4, 2020 to August 26, 2021 (Ex. FED-022; Ex. FED-023; Ex. FED-024; Ex. FED-025; Ex. FED-026); Executive Order 13945 (Ex. FED-066); the Bureau's Regulation X interim rule, Bulletin 2021-02, Regulation F rule and Regulation X final rule (Ex. FED-343; Ex. SEC-13-010; Ex. SEC-13-008; Ex. FED-344), with its Joint Statement of April 3, 2020 as context (Ex. SEC-13-009); the State forbearance mandates of New York, Massachusetts and the District (Ex. NY-013; Ex. NY-100; Ex. MA-052); and the State stays of every quarter (Ex. NH-004; Ex. WA-013; Ex. NJ-003; Ex. CT-015; Ex. NY-020; Ex. NY-083; Ex. NY-085; Ex. NY-086; Ex. MN-006; Ex. MN-026; Ex. MN-042; Ex. AZ-006; Ex. IL-012; Ex. IL-070; Ex. IL-067; Ex. IL-038; Ex. KS-011; Ex. KS-034; Ex. KS-044; Ex. IN-005; Ex. FL-019; Ex. NV-010; Ex. NV-031; Ex. NV-037; Ex. CO-009; Ex. CO-071; Ex. CO-078; Ex. MT-011; Ex. MT-021; Ex. HI-006; Ex. HI-023; Ex. VT-046; Ex. DE-009; Ex. DE-038; Ex. CA-005; Ex. CA-040; Ex. CA-063; Ex. CA-064; Ex. CA-062; Ex. OR-006; Ex. OR-024; Ex. OR-026; Ex. OR-037; Ex. OR-042; Ex. OR-050; Ex. WA-060; Ex. WA-069; Ex. WA-086; Ex. NC-012; Ex. NC-020; Ex. NC-038; Ex. KY-027; Ex. KY-059; Ex. TX-057; Ex. TX-060; Ex. TX-041; Ex. TX-040; Ex. MI-079; Ex. NM-009; Ex. NM-072 (post-period, showing the stay's duration); Ex. CT-103; Ex. MA-053).
The modification
The orders terminated the foreclosure, eviction, repossession and garnishment processes for the periods named, compelled forbearance on attestation and current reporting, imposed new notice, safeguard and communication duties by rule, and placed staffing and forbearance-exit practices under supervisory scrutiny.
The operation of the servicing and collection function was partially suspended, as to foreclosure and eviction terminated, in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the CARES Act, the agency moratoria, the CDC orders, the Bureau's rules and the State stays named above.
IN, insurance
The instruments that reached the function are these: the grace-period, cancellation-moratorium and refund instruments of at least thirty-one States and the District from March 12 to April 15, 2020, several with the force of law (Ex. DE-009; Ex. NJ-012; Ex. NJ-105; Ex. NJ-106; Ex. CA-042; Ex. CA-043; Ex. CA-044; Ex. CA-045; Ex. CA-048; Ex. NY-015; Ex. NY-101; Ex. CT-063; Ex. CT-012; Ex. OK-044; Ex. OK-045; Ex. IN-082; Ex. OH-055; Ex. WI-041; Ex. ME-002; Ex. ME-076; Ex. ME-077; Ex. ME-078; Ex. WV-075; Ex. WV-076; Ex. WV-077; Ex. WV-078; Ex. WA-096; Ex. WA-097; Ex. NC-043; Ex. NC-069; Ex. FL-084; Ex. FL-085; Ex. LA-055; Ex. HI-071; Ex. HI-072; Ex. IA-069; Ex. MO-030; Ex. MO-031; Ex. MO-032; Ex. UT-057; Ex. UT-061; Ex. AL-065; Ex. AL-066; Ex. AK-045; Ex. AK-046; Ex. NV-065; Ex. NH-071; Ex. NH-072; Ex. RI-075; Ex. RI-076; Ex. RI-078; Ex. OR-008; Ex. OR-019; Ex. GA-047; Ex. GA-048; Ex. GA-049; New Mexico's Bulletin 2020-006, Ex. SEC-13-078; Mississippi's Bulletin 2020-3, as amended Mar. 25, 2020, Ex. SEC-13-081; and Texas's Bulletin B-0007-20); the instruments that ran into the third quarter of 2021 (Ex. NJ-012; Ex. IL-011; Ex. ME-002; Ex. GA-050; Ex. GA-055; Ex. GA-056; Ex. WV-078; Ex. VT-070; Ex. LA-056; Ex. DE-038; Ex. CA-048); the FFCRA and CARES coverage mandates, the EBSA tolling and the ARPA subsidy (Ex. FED-170; Ex. SEC-13-023; Ex. SEC-13-024; Ex. SEC-13-020; Ex. SEC-13-021; Ex. SEC-13-022; Ex. FED-174); and the licensing, examination and telework instruments of the insurance departments (Ex. ME-079; Ex. FL-084; Ex. AL-065).
The modification
The orders prohibited cancellation and lapse for nonpayment, compelled refunds, reporting and grace periods, compelled coverage without cost-sharing or prior authorization, tolled deadlines, imposed the subsidy's notice and election duties, and moved agency operations remote with examinations suspended.
The operation of the insurance function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the regulators' cancellation, refund and grace-period orders and the federal coverage, tolling and subsidy mandates named above.
WM, wealth management and advisory
The stay-at-home and gathering orders of every State ended the seminar and the in-person customer review in the second quarter of 2020 and the gathering caps of the reopening and winter orders continued through the second quarter of 2021 (Ex. NY-003; Ex. CA-002; Ex. TX-008; Ex. IL-031; Ex. MN-032); the SEC's exemptive orders of March 2020 and its in-person board relief through September 30, 2021 (Ex. AGY-FED-FINANCIAL-050; Ex. AGY-FED-FINANCIAL-051; Ex. AGY-FED-FINANCIAL-052; Ex. AGY-FED-FINANCIAL-056; Ex. AGY-FED-FINANCIAL-057; Ex. AGY-FED-FINANCIAL-058; Ex. AGY-FED-FINANCIAL-064); the CFTC's no-action letters from March 17, 2020 to September 30, 2021 (Ex. AGY-FED-FINANCIAL-067; Ex. AGY-FED-FINANCIAL-068; Ex. AGY-FED-FINANCIAL-069; Ex. AGY-FED-FINANCIAL-071; Ex. AGY-FED-FINANCIAL-072; Ex. AGY-FED-FINANCIAL-073); FINRA's temporary Rule 3110.17, adopted by SR-FINRA-2020-040 with the Commission's approval, which governed every 2020 and 2021 branch inspection (Ex. AGY-FED-FINANCIAL-076; Regulatory Notices 20-08 and 20-16, Ex. SEC-13-028, Ex. AGY-FED-FINANCIAL-074 and Ex. AGY-FED-FINANCIAL-075, are context); and the indoor face-covering reinstatements of the third quarter of 2021, airborne-transmission controls with a duty on the operator, on every advisory office (Ex. OR-048; Ex. WA-078; Ex. MET-LA-018; Ex. MET-SFO-010; Ex. MET-CHI-026).157
The modification
The orders ended customer meetings and seminars or moved them remote, put supervision and branch inspection on a remote footing under temporary rules, moved fund boards and filings online, and placed offices under the airborne-transmission controls of the third-quarter face-covering reinstatements, with a duty on the operator.
The operation of the wealth-management function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the gathering and stay-at-home orders, the regulators' remote-operation instruments and the face-covering reinstatements named above.
MK, marketing, seminars and member meetings
The instruments that reached the function are these: the gathering caps of every State in 2020 and the winter of 2020-21 (Ex. NY-003; Ex. IL-005; Ex. MN-010; Ex. TX-022; Ex. MET-SLC-021; Ex. MET-BOS-021); the Comptroller's meetings rule of May 28, 2020 (Ex. AGY-FED-FINANCIAL-020), announced by OCC Bulletin 2020-51 (Ex. AGY-FED-FINANCIAL-019, context); NCUA's Letters 20-FCU-02 and 20-FCU-04, guidance that carried the virtual-meeting practice through 2021 (Ex. AGY-FED-FINANCIAL-030; Ex. AGY-FED-FINANCIAL-047, context); the SEC's shareholder-meeting guidance (Ex. AGY-FED-FINANCIAL-053, context); and the gathering conditions of Hawaii, the Virgin Islands and the Delta-wave jurisdictions in the third quarter of 2021 (Ex. HI-025; Ex. AGY-TERRITORIES-066).
The modification
The orders moved annual, member and shareholder meetings online by rule and ended seminars and community events by gathering cap.
The operation of the marketing and meetings function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the gathering caps and the meetings rule named above.
HR, hiring, licensing and examinations
Prometric announced the closure of every United States test center from March 17 to April 30, 2020 under the State closure orders (Ex. AGY-ST-TRADE-BOARDS-033, the vendor's announcement, cited as context); Maine issued temporary producer licenses because its examination centers were closed (Ex. ME-079); Virginia's DPOR and California's DCA waived credential and examination requirements into the third quarter of 2021 (Ex. AGY-ST-TRADE-BOARDS-022; Ex. AGY-ST-TRADE-BOARDS-050); USCIS announced its closure to the public from March 18 to June 4, 2020 (Ex. AGY-FED-LABOR-IMMIGRATION-053 and Ex. AGY-FED-LABOR-IMMIGRATION-056, agency announcements cited as context) and the Department of State suspended routine visa services on March 20, 2020 (Ex. AGY-FED-LABOR-IMMIGRATION-060; Ex. AGY-FED-LABOR-IMMIGRATION-061); Proclamations 10014, 10052, 10131, 10143 and 10199 suspended entry (Ex. FED-210; Ex. FED-211; Ex. FED-213; Ex. FED-207; Ex. FED-208); DHS announced the deferral of the I-9 physical-inspection rule in every quarter (Ex. AGY-FED-LABOR-IMMIGRATION-068, an agency announcement cited as context); and the workplace standards, exposure-prevention plans and Executive Order 14042 governed onboarding and contractor status in the third quarter of 2021 (Ex. ECO-B-120; Ex. AGY-ST-LABOR-WORKPLACE-011; Ex. VA-037; Ex. VA-038; Ex. FED-063).
The modification
The orders cancelled or rescheduled examinations, put licenses on temporary terms, suspended consular and USCIS services, moved onboarding to remote inspection, and conditioned contractor workforces.
The operation of the hiring and licensing function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the licensing waivers, the consular and entry orders and the workplace orders named above, and of the test-center closures the State orders compelled.
OP, back-office operations and supervision
The function ran under the following: the Federal Reserve's announcements of its examination reduction of March 24 and remote resumption of June 15, 2020 (Ex. AGY-FED-FINANCIAL-011; Ex. AGY-FED-FINANCIAL-021, context); the NCUA's letters announcing its strict offsite policy from March 16, 2020 and its staged Phase 1 return from July 19, 2021 (Ex. SEC-13-006; Ex. AGY-FED-FINANCIAL-032; Ex. AGY-FED-FINANCIAL-043; Ex. AGY-FED-FINANCIAL-046; Ex. AGY-FED-FINANCIAL-066, supervisory letters cited as context); the NCUA's and Federal Reserve's temporary relief rules (Ex. AGY-FED-FINANCIAL-039; Ex. AGY-FED-FINANCIAL-048; Ex. AGY-FED-FINANCIAL-049; Ex. AGY-FED-FINANCIAL-010; Ex. AGY-FED-FINANCIAL-018); Montana's branch-closure Proclamations to July 12, 2021 (Ex. MT-041); Nebraska's examination and cash-count waivers to June 1, 2021 (Ex. AGY-ST-DMV-SOS-RECORDERS-046); Iowa's remote-work authorization for licensees (Ex. IA-071); the State telework mandates and workplace standards of every quarter (Ex. NY-003; Ex. PA-022; Ex. WA-047; Ex. ECO-B-045; Ex. AGY-ST-LABOR-WORKPLACE-001; Ex. AGY-ST-LABOR-WORKPLACE-002; Ex. AGY-ST-LABOR-WORKPLACE-050; Ex. AGY-ST-LABOR-WORKPLACE-055; Ex. NY-133; Ex. NJ-050; Ex. VA-037; Ex. VA-038; Ex. OR-032; Ex. OR-041; Ex. OR-049; Ex. ECO-B-044); and the Service's own postponements that governed the industry's tax and information reporting (Ex. AGY-FED-FINANCIAL-078; Ex. AGY-FED-FINANCIAL-082; the Taxpayer Assistance Center closure announcement, Ex. AGY-FED-FINANCIAL-085, as context).
The modification
The orders moved supervision, examination and back-office work off site under the telework mandates and the supervisors' announced offsite policies, closed offices by regulator's leave, and placed workplace standards on every floor.
The operation of the back-office and supervisory function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the telework mandates and the workplace standards named above, under which the supervisors' examinations, as their announcements record, moved off site.
WF, workforce availability
The instruments that reached the function are these: the stay-at-home orders of forty-two States and territories (Ex. LAW-201); the school closures of 2020 and the school face-covering and quarantine orders of the 2021-22 year (Ex. ECO-B-086; Ex. ECO-B-087; Ex. ECO-B-145; Ex. ECO-B-148; Ex. ECO-B-149; Ex. ECO-B-150; Ex. ECO-B-152; Ex. ECO-B-153; Ex. ECO-B-155; Ex. ECO-B-117); the FFCRA leave mandate and rule from April 1 to December 31, 2020 (Ex. FED-170; Ex. FED-171; Ex. FED-172; Ex. AGY-FED-LABOR-IMMIGRATION-001); the isolation and quarantine orders of every quarter (Ex. MET-SAC-016; Ex. MET-SAC-017; Ex. MET-PIT-014; Ex. NY-134; Ex. MET-CIN-046; Ex. MET-RIV-017); the conveyance face-covering order and transit rules from February 1, 2021 (Ex. FED-020; Ex. FED-050; Ex. FED-051; Ex. FED-052; Ex. MET-BAL-105; Ex. MET-BAL-107; Ex. MET-NYC-046; Ex. MET-CLE-042; Ex. MET-MKE-044); the local sick-leave mandates (Ex. MET-PIT-046; Ex. MET-PIT-055; Ex. MET-CIN-030); and Washington's Proclamation 20-46 requiring every employer to accommodate employees at higher hazard from April 13, 2020 to June 28, 2021 (Ex. ECO-B-121).
The modification
The orders confined employees at home, paid them under leave mandates, removed them by quarantine, kept them home by school closures and conditioned their commute.
The operation of the workforce function was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the stay-at-home, school, leave, quarantine and conveyance orders named above.
CB, the customer and member base
The stay-at-home orders of forty-two States and territories, the closure orders of every State, the winter re-tightening and the face-covering and exposure-control orders of every quarter confined the households and businesses that are the industry's customers and members (the fifty States, above); the eviction, foreclosure and utility instruments governed the borrowers themselves (Ex. FED-022; Ex. FED-025; Ex. NJ-003; Ex. NY-085; Ex. CA-062; Ex. WA-069; Ex. IL-038); the Bureau's own counts record the customer base's condition (Ex. SEC-13-010; Ex. SEC-13-034); and the entry proclamations and land-border notices fixed who could cross to transact (Ex. FED-207; Ex. FED-208; Ex. FED-233; Ex. FED-256).158
The modification
The orders confined, closed or conditioned the customers and fixed their capacity to transact, deposit, borrow, pay premium and meet.
The operation of the customer-facing functions of this industry was partially suspended in every quarter from the second quarter of 2020 through the third quarter of 2021 because of the orders on the customer and member base named above, each an order limiting commerce, travel or group meetings under the statute's text and Q&A-12's logic.