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Financial Services Law Insights and Observations

Iowa Division of Banking issues guidance on bank closings and remote work

State Issues Iowa Covid-19

State Issues

On March 18, the Iowa Division of Banking issued regulatory guidance for working from a residence or other company designated location. The guidance allows licensees and registrants, including licensed or registered mortgage loan originators, and their employees, to work remotely from their residence or another location designated by the employer during the COVID-19 pandemic, even if the residence or designated location is not a licensed or registered location. The guidance also provides best practices for remote workers to maintain security.

On March 12, the Iowa Division of Banking (IDOB) issued a statement to presidents and/or CEOs of all state-chartered banks regarding the temporary closure of bank branch offices. The guidance notes that while state banks are not required to get permission from the IDOB to temporarily close a branch office, the IDOB requests that the banks provide notification so that the IDOB can track closures. The guidance also provides that Iowa law permits the IDOB to authorize banks to operate in alternative locations in the event of an emergency. If a bank needs to operate out of a different location as a result of the Covid-19 situation, the bank must contact the bank’s analyst to obtain proper authorization.