Connecticut Extends No Action Letter on Temporary Remote Workers

Connecticut letter addresses branch licensing issues, now in effect through June 30. North Carolina and Ohio also recently released updates on their state reopening plans.

5/21/2020 1:00 PM

COVID-19StateNews
Connecticut Extends No Action Letter on Temporary Remote Workers

The Connecticut Department of Banking extended its no-action memo to address branch licensing issues considering temporary mitigation actions licensees needed to take to continue business due to COVID-19 through June 30, 2020. It was set to expire May 31, 2020.

The department’s no-action position concerns the requirement that any Connecticut licensable activity by a Consumer Credit Licensee be conducted from a licensed branch office location, as long as criteria are met:

  • The Connecticut licensable activity is conducted from the home location of an individual working on behalf of a Connecticut CC Licensee;
  • The individual is working from home due to a reason relating to the COVID-19 outbreak and has informed the Connecticut CC Licensee of such reason in writing;
  • The individual maintains all necessary licenses under Title 36a to conduct such Connecticut licensable activity, including, but not limited to, mortgage loan originator or loan processor or underwriter licensure, as applicable;
  • None of the Connecticut licensable activity will be conducted in person with members of the public from the home location; and
  • The Connecticut CC Licensee shall at all times exercise reasonable supervision of the Connecticut licensable activity being performed at the home office and ensure that appropriate safeguards and controls are established concerning consumer information and data security.

North Carolina

On May 20, Gov. Roy Cooper signed an order to move the state into Phase 2 of its reopening plan. The new order lifts the stay at home order at 5 p.m. Friday, May 22 but individuals are strongly encouraged to telework to the greatest extent permissible by their employer.  Some restrictions will remain in place and certain businesses (bars, gyms, theaters) must remain closed.

Mass gatherings with limited exemptions, more than 10 people indoors or more than 25 people outdoors, continue to be prohibited.

Ohio

On May 20, Gov. Mike DeWine signed a new order that rescinds and modifies the Stay Safe Ohio order and released a new “Ohioans Protecting Ohioans Urgent Health Advisory,” which replaces the Stay Safe Ohio order that was issued by the Ohio Department of Health on April 30, 2020. 

The new health advisory replaces language requiring Ohioans to stay at home with limited exceptions. The advisory strongly recommends that citizens, especially those who are high-risk, stay at home as much as possible. The order does not change the mass gathering restrictions, which remain at a 10-person limit.

The new health advisory also lifts overall travel restrictions and the requirement to quarantine for individuals traveling to or returning to Ohio.

ACA International members may find state updates on our state compliance COVID-19 webpage and are advised to check the National Governors Association  website, which has multiple resources available on COVID-19 in the U.S. and actions in states and territories in response to the pandemic. The resources include a chart  summarizing state actions and business re-openings. Implementation of various state plans are changing all the time and the changes often do not directly impact the accounts receivable management industry (i.e. parks, restaurants, construction, curbside deliveries.)

Members are encouraged to check the chart for their state updates while ACA will continue to highlight specific changes for the industry on a regular basis.

For more information on how the ACA Licensing staff can assist with your licensing needs, please contact us at Licensing@acainternational.org  or call (952) 926-6547.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

Connecticut Extends No Action Letter on Temporary Remote Workers

The Connecticut Department of Banking extended its no-action memo to address branch licensing issues considering temporary mitigation actions licensees needed to take to continue business due to COVID-19 through June 30, 2020. It was set to expire May 31, 2020.

The department’s no-action position concerns the requirement that any Connecticut licensable activity by a Consumer Credit Licensee be conducted from a licensed branch office location, as long as criteria are met:

  • The Connecticut licensable activity is conducted from the home location of an individual working on behalf of a Connecticut CC Licensee;
  • The individual is working from home due to a reason relating to the COVID-19 outbreak and has informed the Connecticut CC Licensee of such reason in writing;
  • The individual maintains all necessary licenses under Title 36a to conduct such Connecticut licensable activity, including, but not limited to, mortgage loan originator or loan processor or underwriter licensure, as applicable;
  • None of the Connecticut licensable activity will be conducted in person with members of the public from the home location; and
  • The Connecticut CC Licensee shall at all times exercise reasonable supervision of the Connecticut licensable activity being performed at the home office and ensure that appropriate safeguards and controls are established concerning consumer information and data security.

North Carolina

On May 20, Gov. Roy Cooper signed an order to move the state into Phase 2 of its reopening plan. The new order lifts the stay at home order at 5 p.m. Friday, May 22 but individuals are strongly encouraged to telework to the greatest extent permissible by their employer.  Some restrictions will remain in place and certain businesses (bars, gyms, theaters) must remain closed.

Mass gatherings with limited exemptions, more than 10 people indoors or more than 25 people outdoors, continue to be prohibited.

Ohio

On May 20, Gov. Mike DeWine signed a new order that rescinds and modifies the Stay Safe Ohio order and released a new “Ohioans Protecting Ohioans Urgent Health Advisory,” which replaces the Stay Safe Ohio order that was issued by the Ohio Department of Health on April 30, 2020. 

The new health advisory replaces language requiring Ohioans to stay at home with limited exceptions. The advisory strongly recommends that citizens, especially those who are high-risk, stay at home as much as possible. The order does not change the mass gathering restrictions, which remain at a 10-person limit.

The new health advisory also lifts overall travel restrictions and the requirement to quarantine for individuals traveling to or returning to Ohio.

ACA International members may find state updates on our state compliance COVID-19 webpage and are advised to check the National Governors Association  website, which has multiple resources available on COVID-19 in the U.S. and actions in states and territories in response to the pandemic. The resources include a chart  summarizing state actions and business re-openings. Implementation of various state plans are changing all the time and the changes often do not directly impact the accounts receivable management industry (i.e. parks, restaurants, construction, curbside deliveries.)

Members are encouraged to check the chart for their state updates while ACA will continue to highlight specific changes for the industry on a regular basis.

For more information on how the ACA Licensing staff can assist with your licensing needs, please contact us at Licensing@acainternational.org  or call (952) 926-6547.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

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