Well, these are uncharted waters, so there isn't a clear answer. The conservative answer, of course, is to go ahead and throw something in your public file about it. That said, your branches aren't really closed, but by appointment only at this point so I'm not sure it would be technically required, but again, the guidance doesn't address this type of situation.
And if you know an auditor or examiner may be looking at your public file, its always easier to be proactive than to fight it after the fact. Either way, I'd call this a very low-risk concern.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com