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VA issues Covid-19 guidance
On March 16, the Department of Veterans Affairs (VA) released Circular 26-20-7, “Special Relief for those Potentially Impacted by COVID-19,” which provides guidance for veterans, lenders, servicers, and appraisers on the VA Home Loan Program in connection with the spread of Covid-19. Veterans are encouraged to call ahead for any in-person appointments with VA staff or with a lender, appraiser, or servicer regarding a home loan if the veteran may present a Covid-19 transmission risk. Additionally, the VA will permit lenders and servicers to offer relief to veterans impacted by the virus through (i) forbearance on guaranteed loan payments; (ii) waiver of late charges; and (iii) suspending credit bureau reporting. Appraisers are encouraged to continue business in accordance with Chapter 10 of the M26-7 Lender’s Handbook. As with the guidance for veterans, appraisers are also encouraged to determine if they present a Covid-19 transmission risk prior to face-to-face appointments, and then, as appropriate, to reschedule appointments or transfer the assignment to another appraiser. The announcement also urges appraisers to follow the Centers for Disease Control and Prevention’s recommendations to prevent the spread of Covid-19 when performing appraisals. The circular notes that the VA “is continuing with normal program operations” and will update information on the VA Home Loan Program as it is available.
Texas Department of Savings and Mortgage Lending issues business continuity, work from home guidance
On March 13, the Texas Department of Savings and Mortgage Lending issued a statement to state savings bank presidents and chief executive officers, reminding them to review their business continuity plans, particularly as they relate to pandemics.
On March 13 and 17, the Texas Office of Consumer Credit Commission issued advisory bulletins to regulated lenders, credit access businesses, property tax lenders, and motor vehicle sales finance licensees regarding responses they can take to Covid-19, including allowing licensees to conduct business activities from unlicensed locations provided certain requirements are met (e.g., the licensee prepares a written plan or document describing next steps and locations where credit access business activity will take place).
On March 16, the Texas Department of Banking issued Industry Notice 2020-03 providing guidance to regulated institutions regarding customer support, pandemic preparedness including tips on emergency closures, and future examinations.
Maine Bureau of Consumer Credit Protection provides guidance to MLOs
On March 18, the Maine Bureau of Consumer Credit Protection provided interim guidance to MLOs, allowing employees to work from home as long as data security provisions are in place, and physical business records are stored only at the licensed main office. The guidance will be effective through May 1, 2020.
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.
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.
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.