Last week, in a blog entitled “Coronavirus Hits Home,” we informed you that we had contacted the Conference of State Bank Supervisors (“CSBS”) and regulators in a number of states to see what CSBS or the state regulators were telling mortgage lender or broker licensees as to whether their licensed MLO employees who had been quarantined in their homes because of the coronavirus (“COVID-19”) could continue to originate mortgage loans from their homes without the home being licensed as a branch office. Since that blog, CSBS has posted certain state-by-state COVID-19 guidance on the NMLS Resource Center, which among other things covers relevant business continuity plans for licensed mortgage loan officers. We urge you to check the NMLS Resource Center and the State Agency websites for the guidance provided.
Since we sent our request to state regulators as to relief from branch licensing for licensed MLOs who are quarantined in their homes, but want to continue to originate mortgage loans, a number of state regulators have responded directly and positively to our email request. As some of the guidance posted on the NMLS website may not cover the branch licensing issue we posed to CSBS and certain other state regulators, we thought it would be helpful to post some of the specific guidance we have received from state regulators that addressed the branch licensing concern raised by our clients.