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Idaho regulator issues remote work guidance to escrow licensees
On March 18, the Idaho Department of Finance issued guidance to entities licensed under the Idaho Escrow Act permitting licensed activities to be conducted from unlicensed residences. The Department stated it will not take action against a licensee so long as the licensable activities meet specified data security and privacy requirements, and the licensee avoids advertising the unlicensed address or phone number, meeting consumers at the residence, or otherwise holding out or suggesting that the residence is a licensed location. The guidance is effective until June 30.
Michigan governor extends property tax redemption payments deadline
On March 18, Michigan Governor Gretchen Whitmer issued an executive order extending the deadline for redemption payments on foreclosed property as a result of delinquent property tax payments, in response to the inability of county treasurers to process redemption payments during the pandemic. Whitmer’s order extended the deadline from March 31 to May 29, or 30 days after the termination of the state of emergency.
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.