Numerous state and federal agencies have issued regulatory and licensing guidance related to the coronavirus/Covid‑19 health emergency. Guidance notes the ability for licensed individuals, primarily mortgage loan originators, to work remotely, and other exceptions to the usual rules to ensure continuity of operations. Regarding the ability for mortgage loan originators to work remotely, companies must provide reasonable supervision and security over the licensable activity even if not at a licensed location. The Washington Department of Financial Institutions specifically notes:
- Individuals must be able to access the company’s secure origination system (including a cloud-based system) directly from any out-of-office device the mortgage loan originator uses (laptop, phone, desktop computer, tablet, etc.) using a virtual private network (VPN) or similar system that requires passwords or other forms of authentication to access.
- All security updates, patches, or other alterations to the device’s security must be maintained.
- Individuals must not keep any physical business records at any location other than the licensed main office.
The Conference of State Bank Supervisors (CSBS) is maintaining a list of links to all relevant coronavirus/Covid‑19 regulatory and licensing guidance on the NMLS Resource Center. Click here to access the most recent version of the list (posted and updated by CSBS).
You can contact our team of licensing professionals for additional information by clicking here.