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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.
Nevada Dept. of Business and Industry issues work from home guidance
On March 13, the Nevada Department of Business and Industry, Division of Mortgage Lending, issued guidance to temporarily allow licensed mortgage loan originators to work from home, including persons associated with principal office locations, branch office locations, and other licensed locations located in other states.
Montana Division of Banking and Financial Institutions issues work from home guidance
The Montana Division of Banking and Financial Institutions has issued guidance temporarily allowing licensed mortgage loan originators to work from home, whether located in Montana or another state, even if the home is not a licensed branch with some conditions.
Mississippi Dept. of Banking and Consumer Finance issues Covid-19 guidance
On March 14, the Mississippi Department of Banking and Consumer Finance (DBCF) issued memoranda to Consumer Finance Licensees and Mortgage Licensees that includes general guidance to the industry and “outline[s] flexibility in DBCF processes in response to the COVID-19 event.” Among other things, the guidance advises licensees to periodically review related risk management plans (specifically continuity and pandemic plans) to ensure continuity of products and services with minimal disruption. It also advises that, if “necessary and appropriate,” licensees may relocate offices or have employees work from home. Additionally, effective March 13, the DBCF will discontinue onsite examinations. During this time, DBCF will be available to assist the industry and consumers via telephone and email communication.
On March 16, the DBCF issued interim guidance allowing mortgage loan originators to temporarily work from home, whether located in Mississippi or another state, even if the home is not a licensed branch provided certain requirements are met.
Maryland Commissioner of Financial Regulation issues Covid-19 guidance
On March 13, the Maryland Commissioner of Financial Regulation issued a bulletin advising that regulated entities should have a comprehensive disaster recovery plan in place that identifies how they will respond to various disasters and emergencies. The bulletin also identifies questions received from regulated entities and the Commissioner’s responses. Specifically, the Commissioner responded to questions regarding working from unlicensed locations, preferred methods of communication with the Commissioner, and notification to the Commissioner if a licensed business is closed because of mass quarantines during any part of an examination.
Massachusetts Division of Banks reminds businesses about continuity plans
On March 11, the Massachusetts Division of Banks issued a reminder that licensees should have in place business continuity plans in relation to Covid-19 and its potential impact on the delivery of financial services. During a period of quarantine or social distancing in homes due to Covid-19, the Division does not require mortgage loan originators’ homes to be licensed as a branch as long as they do not advertise the home as an office and do not meet consumers at their home. The Division would also permit all other licensees to work from home, provided certain conditions are met.
Kansas Office of the State Bank Commissioner issues work from home guidance
On March 16, the Kansas Office of the State Bank Commissioner (OSBC) issued temporary guidance allowing licensed mortgage companies, mortgage loan originators, supervised loan licensees, credit services organizations, money transmitters, credit notification registrants and their employees to work remotely due to the Covid-19 crisis. Licensed or registered individuals and entities will be allowed to work from their residences or a company designated location--even if the residence or location is not a licensed or registered branch location--providing they have temporary policies, procedures, and a plan for supervision in place. OSBC also set forth best practices for remote work to ensure that security of information is maintained.
Connecticut Dept. of Banking issues work from home guidance
On March 9, the Connecticut Department of Banking issued a memorandum indicating that individuals who work for Consumer Credit Licensees currently licensed in Connecticut may temporarily work from home even though such home location is not currently licensed by as a branch office, so long as certain criteria are met.
Arkansas Securities Dept. issues work from home guidance
On March 13, the Arkansas Securities Department issued interim regulatory guidance temporarily allowing licensed mortgage loan officers to work from home even if the home is not a licensed branch location provided that the MLO working from home is in compliance with all state and federal data security requirements.