In the name of safety and security, it is a long-standing rule that face coverings are not allowed in banks. However, the COVID-19 pandemic has forced banks to broaden their definition of security and safety. Banks across the nation have walked back their requirements banning face-coverings from their establishments and have mandated masks to mitigate the spread of the disease. From a public health security perspective, this is undoubtedly in the best interest of both their employees and their patrons. Yet, the negative externalities that result from these new requirements—temporary as we hope they may be—must be considered. As indicated by the Acting Comptroller of the Currency Brian P. Brooks, masks create the "very real risk of increases in bank robberies." See Letter from Acting Comptroller of the Currency Brian Brooks to Mayor Bryan K.Barnett and Tom Cochrane (Jun. 1, 2020), at 2, //www.occ.gov/news-issuances/news-releases/2020/nr-occ-2020-73a.pdf.

It is our law firm's experience that when there is a financial institution robbery, there is an increased chance of harm to an innocent customer.