Connecticut continues to allow remote work arrangements for consumer credit licensees and addresses branch licensing issues.
1/13/2021 15:00
The Connecticut Department of Banking has extended its no-action memo to address branch licensing issues, this time through March 31, 2021.
The memo includes temporary mitigation actions licensees need to take to continue business due to COVID-19.
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 related 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.
In other related news, Washington state has finalized its remote work rule and Washington, D.C., is continuing debt collection restrictions.