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State “Shelter-in-Place” and “Stay-at-Home” Orders

In response to the COVID-19 pandemic, a growing number of states and localities have issued workplace restrictions as part of their efforts to prevent the spread of the disease.  These “shelter-in-place” or “stay-at-home” orders vary in scope and duration, but generally require businesses not considered “essential” to close their physical offices and continue their operations remotely.

Many of the orders list financial institutions as essential businesses and permit critical on site functions to continue, subject to limitations.  Member firms should closely review the applicable state and locality orders’ impacts on their operations, and make any necessary changes.

To aid member firms, FINRA is providing a list of state orders of which FINRA is aware.  While FINRA will update this list periodically as we become aware of changes, the situation is rapidly developing and firms should rely on their local authorities for the latest developments.  If a member firm decides an employee is permitted to report to a physical office location, FINRA suggests that the employee carry documentation explaining that the employee works for an “essential” business, and why the employee’s work requires his or her physical presence in the office.

Several of the state orders, or guidance and FAQs issued in connection with the state orders, refer to the Department of Homeland Security’s Cybersecurity and Infrastructure Agency (“CISA”) Memorandum issued on March 19, 2020. CISA also issued an updated memorandum on March 28, 2020. CISA’s guidance identifies financial services workers as essential to continued infrastructure viability during this tumultuous time. In addition, on March 24, 2020, Treasury Secretary Steven T. Mnuchin issued a statement that he “strongly support[s] the Department of Homeland Security’s recent guidance identifying financial services sector workers as essential critical infrastructure workers during the COVID-19 response emergency.”

To the extent that member firms are aware of state orders not listed below, please contact FINRA’s Office of Government Affairs at [email protected] with information regarding the orders.

State Order and Related Materials Order Date
Alabama Order of the State Health Officer Suspending Certain Public Gatherings Due to Risk of Infection by COVID-19   4/3/2020
Alaska Heath Mandate 011 - Social Distancing Alaska Essential Services and Critical Workforce Infrastructure Order 3/27/2020
Arizona Executive Order 2020-18 Executive Order 2020-12 3/30/2020
California Executive Order N-33-20   3/19/2020
Colorado D 2020 017 Executive Order Amended Public Health Order 20-24 Implementing Stay at Home Requirements 3/25/2020
Connecticut Executive Order 7H Guidance from Dept. of Economic and Community Development 3/20/2020
Delaware Fourth and Fifth Modifications of the Declaration of A State of Emergency for the State of Delaware Due to a Public Health Threat List of Essential and Non-Essential Businesses 3/22/2020
District of Columbia Mayor’s Order 2020-054 Mayor's Order 2020-053 3/30/2020
Florida Executive Order Number 20-91 Executive Order Number 20-89 4/1/2020
Georgia Executive Order   4/2/2020
Hawaii Third Supplementary Proclamation   3/23/2020
Idaho Order to Self-Isolate The Office of the Governor Extreme Emergency Proclamation  3/25/2020
Illinois Executive Order 2020-10 Executive Order 2020-18 3/20/2020
Indiana Executive Order 20-08  FAQ for order 3/23/2020
Kansas Executive Order No. 20-16   3/28/2020
Kentucky Executive Order 2020-246   3/22/2020
Louisiana Proclamation Number 33 JBE 2020   3/22/2020
Maine Executive Order 28 FY 19/20 Executive Order No. 19 FY 19/20 3/31/2020
Maryland Order of the Governor of the State of Maryland Number 20-03-23-01 Interpretive Guidance Re Order Number 20-03-23-01 dated March 23, 2020 3/30/2020
Massachusetts COVID-19 Order No. 13 Exhibit A - COVID-19 Essential Services 3/23/2020
Michigan Executive Order 2020-21 (COVID-19)   3/23/2020
Minnesota Emergency Executive Order 20-20 Directing Minnesotans to Stay at Home   3/25/2020
Mississippi Executive Order No. 1466 Executive Order No. 1463 4/1/2020
Missouri Stay Home Missouri   4/3/2020
Montana Stay at Home Directive   3/26/2020
Nevada  Declaration of Emergency for COVID-19 - Directive 010 - Stay at Home Order Department of Public Safety Division of Emergency Management Emergency Regulation NAC 414 3/31/2020
New Hampshire Emergency Order #17 Pursuant to Executive Order 2020-04 Exhibit A to Emergency Order #17 3/26/2020
New Jersey Executive Order No. 107
Executive Order No. 108
New Mexico Public Health Emergency Order Closing  All Businesses and Non-Profit
Entities Except for those Deemed Essential and
Providing Additional Restrictions on Mass Gatherings Due to COVID-19
New York Executive Order 202.6
Executive Order 202.8
North Carolina Executive Order No. 121   3/27/2020
Ohio Dept. of Health - Director's Stay at Home Order   3/22/2020
Oklahoma Seventh Amended Executive Order 2020-07   4/1/2020
Oregon Executive Order No. 20-12   3/23/2020
Pennsylvania Order of the Governor of the State of Pennsylvania for Individuals to Stay at Home Industry Operation Guidance 4/1/2020
Puerto Rico Administrative Bulletin No. OE-2020-023   3/15/2020
Rhode Island Executive Order 20-13 COVID-19 Business Checklist 3/30/2020
South Carolina Executive Order No. 2020-21   4/6/2020
South Dakota Executive Order 2020-08   3/23/2020
Tennessee Executive Order by the Governor 22   3/30/2020
Texas Executive Order No. GA-14 GA-14 Essential Services Designation 3/31/2020
Utah The Governor's Coronavirus Directive for Utah - "Stay Safe, Stay Home"   3/27/2020
Vermont Stay Home, Stay Safe Order (Addendum 6 to Executive Order 01-20)   3/24/2020
Virginia Executive Order Number 55 (2020) Executive Order Number 53 (2020) 3/30/2020
Washington Proclamation 20-25 Proclamation 20-25 Appendix  3/23/2020
West Virginia Executive Order No. 9-20   3/23/2020
Wisconsin Emergency Order #12    3/24/2020

List updated on 4/7/2020