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Financial Services Law Insights and Observations

West Virginia regulator permits financial institution employees to work remotely

State Issues State Regulators West Virginia Mortgages Loan Origination Covid-19

State Issues

On March 13, the West Virginia Division of Financial Institutions issued temporary guidance permitting employees of regulated entities to work from home or another remote location approved by the financial institution. Temporary assignments under the guidance are permitted from March 13 through May 1. The Division emphasized that regulated institutions should ensure that privacy and security issues are adequately addressed. The Division reminded depository entities of the prior notice requirements for branch closures or limited service, and requested that they review and implement pandemic preparedness plans. The guidance also addressed requirements specific to mortgage loan originators, indicating that they must, among other things, maintain records identifying the dates and locations where each licensed originator worked remotely and have current and approved policies for access to secure origination systems.  In addition, MLOs and other employees working remotely may not meet with borrowers at an unlicensed branch location.