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2 June 2021

Vermont Eliminates Combination License And Codifies Remote-Work For MLOs

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Ballard Spahr LLP

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Permitting mortgage loans originators (MLOs) and employees of other nonbank licensees to work from home without obtaining a branch license for their residence.
United States Vermont Finance and Banking

The Vermont legislature recently made amendments to its licensing statutes, which include the following, among others:

  • Eliminating the Combination License, which allowed companies to apply for and receive a combination of up to four license types (Lender, Mortgage Broker, Loan Solicitation, and Loan Servicer Licenses) at a discounted fee. Implementation of the concept within the Nationwide Multistate Licensing System (NMLS) has posed issues with reporting and public records requests, and therefore, elimination of the license will now require companies to apply for the licenses separately as done so previously.
  • Permitting mortgage loans originators (MLOs) and employees of other nonbank licensees to work from home without obtaining a branch license for their residence. This amendment codifies practices currently allowed under the emergency rules issued during the COVID-19 health emergency.
  • Increasing penalties for failure to comply with annual reporting requirements applicable to nonbank licensees, including Licensed Lenders, Mortgage Brokers, and Loan Servicers, from $100 to $1,000 for each month the report is past due.

The amendments are currently effective.

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