Dear Clients and Friends:
So, you have sent everyone home to work remotely. You’re washing your hands to a nub and holding your breath when you pass anyone, at any distance. The CDC website is saved to your favorites. You have been reacting to one fire after another as you stabilize your business in the face of the current and evolving crisis. And worrying. About everything.
Time to take a breath. Take stock of what you have accomplished so far to protect and resume your business. Pat yourself and your team on the back – no one could have done better for your company! Is there anything else you could be doing proactively?
Consider these items:
Monitoring for Changes in Stay at Home Orders
If you have not already, sign up for the websites and email notification addresses of the local, state and national emergency management agencies which govern your business locations. You may find that some locations will be released from stay at home orders before others. Discuss with your team how to handle a staggered schedule of return to work and location re-openings. Consult with your outside counsel on your options for recalling employees to their usual work locations. Communicate with your managers and staff often so the transition back to usual operations is as smooth as possible.
Work from Home
Want to monitor what the state regulators are saying about MLOs working from home and other concerns?
Checkout the NMLS Resource Center and their COVID-19 page.
Licensing and Examinations
Fortunately, we are between annual license renewal windows right now. However, you may have MLOs in process of onboarding or terminating, company license items to resolve and similar licensing administrative tasks. Or a state exam in process. Continue to work on these as much as possible.
Extensions
Do not let any deadlines pass. If, due to COVID-19, you are staffing challenged or unable to obtain a license item from a 3rd party, as examples, check the NMLS Resource Center for information on deadline extensions, call the NMLS Help Desk or contact the state(s) in question and request guidance.
NMLS COVID-19 Resource Page
Review insurance policies
Check your insurance policies for business resumption coverage, coverage for loan losses or business losses due to loss of market and so on.
Maintain key organizational functions (and you thought it was all about making loans)
Payroll & Benefits
HR/Employee Relations
Accounting/Finance
IT/Network
Licensing – NMLS administration
State reports – annual and other reports outside of the NMLS
Insurance policy renewals
Board meetings – teleconference – hold them anyway and keep minutes, shows continuity, management and leadership
Monitor internal deadlines and deliverables
Review and prioritize what may need continued support now, or be extended, postponed or cancelled. Consider everything from those scheduled staff and committee meetings to internal reporting deadlines to vendor services such as your quality control audits. Be sure to document these decisions for the Board and for your business recovery planning. Communicate these decisions to management and staff in real time.
Document your business recovery efforts, all of them, whether they were effective or not.
Do it in this moment. Hold ongoing business recovery team meetings during the emergency and keep minutes. When the stay at home orders are lifted and your company resumes usual operations, hold after action meeting(s) with your employees and management to understand what went well and what to do differently next time. Retain these records for a minimum of 3 years. Incorporate your lessons learned into your policies and procedures, training, marketing and corporate culture.
SBA loan options
Is your company eligible? It might be worth checking out. Here is the website: https://www.sba.gov/
What can you and your team accomplish with downtime?
Even if you are not making as many loans, you can position your company and employees to hit the ground running when the all clear sounds.
Plan for your return to usual operations
Consider an all employee meeting to welcome everyone back, reiterate company goals, provide a state of the company message and a chance to get back in touch as a team. Teleconferencing is the new normal, more than ever. Incorporate attendance by teleconference to demonstrate the capability and to gain a comfort level for working and collaborating in that medium.
Employee online training
This year finish all that pesky compliance training ahead of plan. Stay on top of your MLOs – they should be completing their annual NMLS required continuing education as planned so that renewals can happen on time.
Data integrity analysis
Affects your HMDA, Call Reports and other reporting. You will still have to file your regulatory reports so stay on top of your data.
IT/IS risk assessment
Now may be a good time to start a Technology and Information Security Risk Assessment. This can be an eye-opening exercise. What you learn will position you for informed strategic planning for your technology and information management resources.
You have already started.
You are documenting your efforts in the current crisis, such as adding VPN or other secure network capacity. Incorporate what you learn in your risk assessment along with your mitigation plans.
Need a resource?
The FFIEC publishes https://www.ffiec.gov/cyberassessmenttool.htm
Update your P&P!
Not only is this a necessary periodic exercise, but now may present opportunities to engage staff and managers in this process. After all, who knows what they do each day better than the person doing the job.
Marketing
You may choose to hold off on spending for marketing or perhaps you will shift your messaging for the current COVID 19 experience. This may be a good time to perform a website compliance review (think privacy, ADA, rates, program terms, etc.). Keep up with your social media monitoring.
Remember
All the same marketing related regulations apply including rules around consent to contact the consumer.
The Firstline team can help. Email us at info@firstlinecompliance.com or call 636-399-0169.