6. The Department asked Respondent if it had conducted documented reviews of alternate work locations. Respondent confirmed to the examiner that it does not conduct a documented review of alternate work locations following the initial approval of each location. During 2025, Respondent revised its Remote Work Policy to include an annual, virtual review of the remote employee's physical work location and equipment, and to require a management countersignature confirming that the work location satisfies all statutory requirements.
KRS 286.8-010(2) states that “Alternate work location”:
Means a physical location, other than the principal office or a branch, at which the employees of a licensee are authorized by the licensee to remotely engage in the mortgage lending process; and
May include a physical location, other than the principal office or a branch, where an employee:
Completes mortgage-related activities if the location is not maintained or utilized for the purpose of conducting in-person mortgage lending business; and
Meets in person at the convenience of the borrower on an infrequent or as-needed basis in order to complete the mortgage lending process if the location is not the employee's home.
KRS 286.8-036(6) states.
A licensee may permit employees to engage in the mortgage lending process at an alternate work location if:
The licensee has written policies and procedures for supervision of employees working from alternate work locations;
Access to the licensee's computer systems and customer information is in accordance with the licensee's comprehensive written information technology security plan;
Employees are not permitted to conduct in-person customer activities at the alternate work location except as provided in KRS 286.8-010(2)(b)2.;
Page 2 of 8