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Ex. IA-071 Order Primary source read

Regulatory Guidance for Working from Residence or Other Company Designated Location

Guidance allowing licensed mortgage bankers, brokers, servicers and loan originators, regulated and industrial loan licensees, delayed deposit and money services businesses and their employees to work from residences or employer-designated locations that are not licensed locations

Iowa Division of Banking (Finance Bureau Chief Rodney Reed) · Iowa (Sector regulator)

The COVID Project

The record

Jurisdiction
Iowa
Level
Sector regulator
Authority
Iowa Code chs. 535B, 535D, 536, 536A, 533D, 533C (licensed-location requirements); Governor's March 9, 2020 proclamation
Issued
2020-03-18 Mar. 18, 2020
Effective
Immediately, until further notice (read as 2020-03-18)
End
Until further notice (the NMLS record shows it in force through 2020-21) (read as 2021-09-30)
In force
Mar. 18, 2020 to Sept. 30, 2021
Quarters
2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
Limitation types
Telework mandateOther
Addressees
  • Iowa licensed and registered mortgage bankers, brokers, servicers and loan originators; regulated and industrial loan licensees; delayed deposit services and money services businesses
Functions reached
  • ML mortgage lending operations moved to residences
  • OF/OP offices
  • CL consumer lending
Collection
Iowa IA

Operative words

'On March 14, Governor Reynolds announced that due to the detection of community spread Iowans should do their part to protect their health and the health of others by, among other things, considering working remotely.... While Iowa law generally requires that licensed mortgage bankers, mortgage brokers, mortgage servicers, mortgage loan originators, regulated and industrial loan companies, delayed deposit services businesses, and money services businesses conduct business only from a licensed location approved by the IDOB, this guidance (effective immediately and until further notice) expresses the intent of the IDOB to allow licensees and registrants, including licensed or registered mortgage loan originators, and their employees to work remotely from their residence or another location designated by the employer during the COVID-19 pandemic, even if the residence or designated location is not a licensed or registered location.... All licensed companies must have temporary policies, procedures, and a plan for supervision of employees in place.'

Enforcement

Licensing law (Iowa Code chs. 535B et seq.) as modified by the guidance; licensees must adopt remote-work policies and supervision plans

Notes

Evidence of the regulator's own finding that remote work was the expected mode for Iowa's licensed lenders from March 18, 2020.

Retrieval note

The Division's letter (on its letterhead) read in full from the NMLS Resource Center copy.