Following in step with the extensions of its governor's peacetime emergency declaration, Minnesota's Commerce Department has yet again extended its allowance for debt collectors to work from home without branch licensing for the home locations. This is the second extension of the work-from-home guidance, which was originally issued on March 13 and extended for the first time on April 24.
Like the initial guidance and first extension, the most recent extension—issued on Friday, May 15—reiterates the four criteria required in order to receive the benefit of the Department's decision to take no action against agencies who temporarily allow their collectors to work from home. The criteria are:
- The activity is conducted from the home location of an individual working on behalf of a Minnesota licensee;
- The individual is working from home due to a reason relating to the COVID-19 outbreak and has informed the licensee of such reason.
- None of the activity will be conducted in person with members of the public from the home location; and
- The licensee shall, at all times, exercise supervision of the activity being performed at the home office and ensure that appropriate safeguards and controls are in place to protect consumer information and data.
The notice states:
The Commissioner recognizes that because of the concern surrounding the COVID‐19 outbreak, and in light of the Governor’s Executive Orders, individual collectors should be working from home temporarily to protect themselves and others, even though their home location is not currently licensed as a branch office.