work at remote locations. A licensee may permit its employees or independent contractors to work at remote locations in compliance with the licensee’s written policies and procedures subject to the following conditions: 1. The licensee has written policies and procedures for supervision of employees and independent contractors working from remote locations; 2. Access to a licensee’s platforms and customer information shall be in accordance with the licensee’s comprehensive written information security plan; 3. No in-person customer interaction shall occur at an employee’s or independent contractor’s residence unless such residence is a licensed or registered location; 4. Physical records shall not be maintained at a remote location; 5. Interactions with and conversations about consumers shall be in compliance with federal and state information security requirements, including applicable provisions under the Gramm-Leach- Bliley Act and the Safeguards Rule established under the Federal Trade Commission, set forth in 16 CFR Part 314, as such may be amended from time to time; 6. Employees or independent contractors working at a remote location shall have access to the licensee’s secure systems, including a cloud-based system, directly from any out-of-office device that such employee or independent contractor may use including, but not limited to, a laptop, mobile phone, desktop computer, or tablet, via a virtual private network, or comparable system, that ensures secure connectivity and requires passwords or forms of authentication to access; 7. The licensee shall ensure that appropriate security updates, patches, or other alterations to the security of all devices used at remote locations are installed and maintained; 8. The licensee shall have an ability to remotely lock or erase company-related contents of any device or other otherwise remotely limit all access to the licensee’s secure systems; and 9. The Nationwide Multistate Licensing System and Registry record of a mortgage loan originator that works from a remote location shall designate the principal place of business as his or her registered location unless such mortgage loan originator elects to choose a licensed branch office as a registered location.
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