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County clerk office closures
We have become aware of several county clerk offices that are closing or limiting access to the public (e.g., by appointment only, accepting e-records or mail recordings only, open for recording only) in response to Covid-19. Institutions should reach out to their title insurers to determine how they will handle transactions.
Wisconsin Dept. of Financial Institutions issues Covid-19 guidance; allows MLOs to work from home
The Wisconsin Department of Financial Institutions, Division of Banking published a website providing regulated entities with Covid-19 information and resources. The Division also noted that it will take a no-action position concerning a licensed mortgage loan originator working from a location that is not the licensed or registered office or branch office upon compliance with certain criteria.
Washington Dept. of Financial Institutions issues work from home guidance
On March 5, the Washington Department of Financial Institutions, Division of Consumer Services issued interim regulatory guidance expressing the Department’s intent to temporarily allow licensed mortgage loan originators to work from home, whether located in Washington State or another state, even if the home is not a licensed branch provided certain conditions are met. The Department also published a website providing Covid-19 resources for DFI licensees.
Vermont Dept. of Financial Regulation allows MLOs to work from home
On March 13, the Vermont Department of Financial Regulation issued a memorandum advising licensees and sponsoring companies that the Department will not take action against licensed mortgage loan originators and their sponsoring company if the MLO works from home so long as certain requirements are met.
Utah Dept. of Financial Institutions approves suspended/reduced hours
On March 12, the Utah Department of Financial Institutions sent an email permitting regulated entities to temporarily reduce or suspend operations or reduce operating hours without Department approval so long as the entity provides adequate notice to customers and sends an email to the Department informing it of the actions taken.
The Utah Department of Commerce, Division of Real Estate announced on their website that due to Covid-19 concerns, real estate and appraisal licensees that have not completed their RAP Back Fingerprinting enrollment in advance of their March or April 2020 license renewal will have their license expirations temporarily postponed until further notice.
South Dakota Division of Banking issues work from home guidance
On March 12, the South Dakota Division of Banking issued Memorandum 11-003 providing interim regulatory guidance allowing licensed mortgage loan originators to work from home, whether located in South Dakota or another state, even if the home is not a previously authorized location, so long as certain conditions are met.
Rhode Island Dept. of Business Regulation issues work from home guidance
On March 13, the Rhode Island Department of Business Regulation, Banking Division issued Banking Bulletin 2020-1 providing interim regulatory guidance allowing licensed mortgage loan originations to work from home, whether located in Rhode Island or another state, even if the home is not a licensed branch subject to certain conditions.
Oregon Division of Financial Regulation issues work from home guidance
On March 12, the Oregon Division of Financial Regulation (DFR) issued Bulletin No. DFR 2020-6 temporarily authorizing Oregon-licensed mortgage loan originators and other employees of Oregon licensed mortgage lenders, mortgage loan services, consumer finance companies, payday/title lenders, and manufactured structure dealers to work from home while transacting business when certain conditions are met.
Oklahoma Dept. of Consumer Credit issues Covid-19 guidance
On March 13, the Oklahoma Department of Consumer Credit issued interim guidance outlining requirements for the temporary operations from home and alternate locations and expedited change of address and temporary fee waivers for licensed locations that are compromised and/or undergoing decontamination procedures.
Ohio Dept. of Commerce communicates with banks about closures
The Ohio Department of Commerce, Division of Financial Institutions sent out an email reminding Ohio bankers that temporary emergency closures of banking locations must be reported and closures lasting longer than two consecutive days must receive advance approval.