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Financial Services Law Insights and Observations

Nebraska Dept. of Banking and Finance issues MLO guidance

State Issues Mortgages Loan Origination Covid-19 Nebraska

State Issues

On March 12, the Nebraska Department of Banking and Finance (NBFD) issued guidance on temporary branch locations outside of the NMLS upon notification. Pursuant to the guidance, licensed and sponsored mortgage loan originators may temporarily work from an unlicensed branch, including a home office, provided certain conditions are met.

On March 16, the NBFD issued guidance on annual meetings of credit union members, which are required by the Nebraska Credit Union Act. Pursuant to the guidance, Nebraska state-chartered credit unions may postpone their annual meetings of members if the meetings are to be held during the months of March, April, May, or June 2020. The board of directors of a credit union may reschedule the postponed annual meeting so that it will be held in July 2020 or August 2020 and provide members with thirty (30) days prior written or electronic notice of the rescheduled meetings. Records related to the rescheduling of the annual meeting must be kept for the Department’s review. All other provisions of the Nebraska Credit Union Act will remain in place.

On March 17, the NBFD summarized regulatory assistance that it is considering until the state of emergency has lifted. For example, the guidance suggests efforts that financial institutions may take when working with customers, such as allowing shortened hours, reducing customer contact, updating signage relative to hours and locations, allowing customers to defer, skip payments, or extend payment due dates, etc. The guidance also summarizes the NBFD’s position with respect to financial condition review, supervisory response, regulatory relief, regulatory reporting requirements, and alternative service options for customers. The guidance provides additional information on examinations, digital applications, and audits.