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Connecticut No-Action Letter on Temporary Remote Workers in Effect Through Dec. 31


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Connecticut letter addresses branch licensing issues and allows remote work arrangements for consumer credit licensees to continue.

8/24/2020 10:30

The Connecticut Department of Banking extended its no-action memo to address branch licensing issues through the end of the year.

The memo, which includes temporary mitigation actions licensees need to take to continue business due to COVID-19, was set to expire on Aug. 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 these 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.

The Idaho Department of Finance also recently extended its remote work guidance through Dec. 31, 2020, ACA International previously reported.

For the latest on state compliance updates, members are invited to join the next ACA Huddle at 11 a.m. CDT, Wednesday, Aug. 26.

For more information on how the ACA Licensing staff can assist with your licensing needs, please contact us at l[email protected] or call (952) 926-6547.

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