Editor's Note: We at insideARM will keep this article updated with state guidance as it comes out. If you hear of a state that puts forward temporary guidance that is not already on this list, please let us know at email@example.com.
List of updates, see list in article for state details:
- 3/16/2020 at 3:26 PM Eastern: Added Kansas.
Amid the COVID-19 outbreak, there is a push for allowing remote work for typically non-remote jobs in order to slow the spread of the virus. In order to protect the health and safety of our colleagues and friends in the industry, The iA Institute announced today that it will make its Strategy & Tech conference virtual. Similarly, several state regulators have taken this issue seriously and have relaxed their work-from-home licensing requirements for debt collection agents. Typically, in order to work out of their residence, a debt collector would need to register his or her address as a branch office with state regulators. Several states are temporarily allowing an exception to this requirement.
The states that have thus far made announcements include:
- Oregon (email sent to licensees)
- Massachusetts (email sent to licensees)
- Michigan (not quite as clear, but a memo from Mich. Dept. of Health and Human Services recommends working from home "when feasible")
Is your state on the list?
If you collect in one of the above states and plan on proceeding with allowing your employees to work from home, there are two critical things you need to keep in mind. First, you need to read the announcements carefully to make sure you fall within the guidelines and that you are informed of exactly what your collectors can and cannot do. Second, before you proceed, ensure that you create and are able to manage proper policies and procedures regarding remote work for your collectors. Some questions to think of are how will you protect consumer data in a remote environment, and whether your creditor clients will permit such a temporary change.
Is your state not on the list?
Considering the seriousness of this outbreak, it might be worth reaching out to the state regulators and licensing authorities who have not yet issued such an announcement and ask if they would consider it.