The COVID Project
The record
- Jurisdiction
- Colorado
- Level
- State
- Authority
- C.R.S. §§ 5-2-302, 5-16-119(6), 5-19-206, 5-20-106(9) (licensed-location requirements); CDC and CDPHE recommendations (recited)
- Issued
- 2020-03-20 Mar. 20, 2020
- Effective
- 2020-03-20, 'during the pendency of the COVID-19 outbreak'; 'may be amended, revised, or extended at any time' (read as 2020-03-20)
- End
- Not stated (read as 2021-09-30)
- In force
- Mar. 20, 2020 to Sept. 30, 2021
- Quarters
- 2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
- Limitation types
- Telework mandateOperating condition
- Addressees
- specified businesses (entities licensed, registered or filing notification with the Consumer Credit Unit)
- Character
- guidance incorporated
- Collection
- Standing duties: Colorado DUT-CO
Operative words
The Administrator does not intend to take an administrative, disciplinary, or enforcement action for such activities, so long as the following criteria are met:... 6. The individual ceases conducting the activity from the home location as soon as reasonably possible, consistent with recommendations from the CDC, CDPHE, and applicable state health departments.
Penalty
None imposed; the instrument is a conditional non-enforcement position ('does not intend to take an administrative, disciplinary, or enforcement action... so long as the following criteria are met'); it 'does not constitute a statutory or regulatory exemption from licensure'
What it required
A State licensing regulator conditioned its forbearance from enforcing statutory licensed-location requirements against supervised lenders, collection agencies, debt-management providers and student-loan servicers whose employees worked from home on six conditions, including no in-person public contact at the home, reasonable supervision and data safeguards, and return to the office consistent with CDC and CDPHE recommendations; collection agencies keeping a public office were permitted to impose 'reasonable protections consistent with guidance from the CDC and CDPHE'.
Retrieval noteRecorded exactly as a recommendation-conditioned forbearance, not as a duty: the verbs are 'does not intend', 'so long as', 'are advised', 'strongly encouraged'. Its value is as a sector regulator's contemporaneous recognition (Mar. 20, 2020) that licensees 'may be required, or wish, to work from home to avoid further spread of the outbreak' and that the return to licensed offices was to track CDC and CDPHE recommendations. Relevant to IND financial services (telework of licensed staff).