The state’s no-action order on remote work expired June 30, but the Department of Banking extended the remote work option through recent legislation.
7/1/2021 9:00
Connecticut’s no-action position on remote work, enacted in March 2020, allowed individuals engaged in certain licensable activity on behalf of consumer credit licensees to work from remote office locations not licensed as branch office locations. While the no-action order expired June 30, 2021, Banking Commissioner Jorge L. Perez extended the remote work option pursuant to the recently enacted authority set forth in Section 205 of S.B. 1202 of the June Special Session of the Connecticut General Assembly, according to the Department of Banking’s order.
The order covers consumer collection agencies, debt adjusters, debt negotiators, mortgage brokers, mortgage services, sales finance companies, small loan companies and student loan servicers.
Standards for remote work as outlined in the order require licensees to:
- Maintain records identifying the dates of authorized remote office activity, the location of each remote office at which it conducts business and the names of all individuals authorized to conduct business at each remote office location;
- Implement policies and procedures to ensure reasonable supervision over its remote office activities;
- Ensure that no records of licensable activity are maintained at the remote office location;
- Ensure that any individual working from the remote office location is licensed under Title 36a to conduct such remote office activity, as applicable;
- Not meet with members of the public at such remote office location or otherwise hold out the remote office location as an office location to members of the public;
- For any licensed individual conducting business from a remote office location, designate a licensed branch office or main office location as the location of business on the system, as defined in Section 36a-2 of the Connecticut General Statutes;
- Ensure that consumer and licensee information and records concerning the remote office activity remain accessible and available for regulatory oversight and examination; and
- Establish safeguards and controls concerning personal information and data security at the remote office location consistent with existing requirements at licensed locations and applicable state and federal law, including but not limited to, utilizing a virtual private network (VPN) or comparable system that ensures secure connectivity and requires passwords or other forms of authentication to access records, and ensuring that appropriate security updates, patches or other alterations to the security of all devices used at remote office locations are installed and maintained.
The order will remain in effect until modified, superseded or vacated by the Connecticut Department of Banking.
For more information on how the ACA licensing staff can assist with your licensing application completion needs, please contact us at [email protected] or call (952) 926-6547.