Remote Work Best Practices
September 29, 2022 BY MQMR Blogger
With more and more states permitting permanent remote work, what are some best practices mortgage lenders should implement?
1. Ensuring the remote work location meets specific state requirements
● Many states require the remote work location to be the loan originator’s residence and not a commercial space or a space leased by the Company.
2. Maintaining a list of all remote work locations● Many states require and will likely request this list as part of examinations.
3. Developing and adhering to a supervision plan for overseeing remote employees
● States require lenders to develop written policies and procedures surrounding remote work. Policies and procedures should address, at a
minimum, (i) acceptable remote work locations, (ii) information security and privacy requirements, (iii) training, and (iv) employee oversight and
supervision methods, such as through meetings, compliance audits/inspections, and quality control reviews.
4. Ensuring proper security protocols● States prohibit employees from maintaining customer records or documents at remote work locations.
● Lenders must ensure equipment used at remote work locations and network access meet industry standards and specific state requirements.
5. Training remote employees on permissible and impermissible activities
● Employees must understand that they cannot meet with consumers at remote office locations or hold the locations out to the public through
signage, advertising, business cards, or otherwise.
● Employees must understand that customer records and other company data should not be stored at the remote office location.
6. Monitoring● Licensees must ensure compliance with statutory requirements either through physical inspections or other forms of review and testing.
There are several best practices mortgage lenders should implement to compliantly permit employees to work remotely. These include, but are not necessarily limited to: