COVID-19 State Agency Communication / Guidance on Coronavirus / COVID-19

WBK hasWeiner prepared the below chart of coronavirus-related Brodsky communications from Kider state mortgage regulators, PC for use in our state licensing practice. We are making it available on this webpage as well, for your reference. Please note that it should not be considered legal advice. Agencies are updating their guidance regularly, so please use this chart as a starting point, but always confirm that you are looking at the most up-to-date guidance for a given agency.

Update: 03/20/20 – 11/12/20 State / Agency Source / Document Date Expiration Update (Published/ Date Effective) NMLS NMLS Enhancement for 5/8/2020  “The window for licensees to complete fingerprinting Temporary Change to (effective requirements has been temporarily extended 60 days. Fingerprint Windows, 05/11/20)f Licensees will now have 240 days to complete the Effective May 11 requirement, instead of the standard 180 days. The additional 60 days will apply to any expiration window that is currently open or subsequently opened. The additional 60 days will also apply to expiration windows that have expired since March 17. NMLS will be updated May 11, to reflect this temporary change.” Testing Effective  NMLS announced that the Prometric test centers, where open, 06/01/20 are resuming testing for all programs (including nonessential testing), effective June 1. A list of site opening status is available here.  “Once your test enrollment is opened, you will have 180 days to schedule your testing appointment and take the test. If you do not take your test within 180 days, your enrollment window will be closed, you will lose your test enrollment fee and you will have to open and pay for a new enrollment.” Reminder: Recommended 06/05/20  NMLS issued a reminder that the “recommended leniency Leniency Period for Call period for Mortgage Call Report and Money Services Report Filings Businesses Call Report filings is 30 days from the due date, June 14.” Pandemic Planning 03/12/20  The memorandum reminds and encourages to update business continuity planning and follow guidance about 1 State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Alabama / State COVID-19 issued by the Alabama Public Health website, as Banking well as the CDC (e.g., CDC Guidance for Businesses and Department Employers to Plan and Respond to Coronavirus Diseases 2019).  Licensees are encouraged to communicate with impacted consumers regarding deferring fees or other charges.  Licensees may relocate offices or have employees work from home. “Licensees should immediately notify the Department of any circumstances that require the closure, relocation, or remote work program and any efforts taken to work with customers.” Note, proper notification and communication with consumers is required.  The Department plans to maintain normal operations regarding and examination. NMLS State Agency 03/20/20  Only essential AL State Banking Department personnel are Operating Status (effective working. spreadsheet 03/23/20) Agency Homepage 03/31/20  “Procedures for Sending Mail and Email to the Department: To support this organizational change, we have established a central electronic mail account to receive essential correspondence from our financial institutions. If possible, we ask that instead of sending physical mail, send essential correspondence to the email address listed below. Please ensure that all electronic mail that is Confidential Supervisory Information is sent to the Department secured and encrypted. The Department is committed to processing all correspondence in a timely manner. [email protected]” Memorandum: Licensee 04/29/20  The Supervisor of Bureau of Loans, Scott Corscadden, issued Information a memorandum to all licensees after receiving “numerous responses from licensees regarding store closures, remote

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC staffing issues, and actions taken to assist customers during this unprecedented time.”  The memorandum reminds licensees that the Bureau of Loans is “encouraging licensees to work proactively with customers and consider all options to assist those customers impacted by the pandemic” and requests that all licensees keep the Bureau of Loans informed of efforts taken.  “We are also reminding all licensees that they should work with their customers to make sure they are aware of the potential for scams during this time. Our licensees often serve as a source of financial information for many customers, including the elderly and those on fixed incomes. Please notify the Department of any suspicious lending-related activity. The Department will pursue any actor engaged in deceptive or abusive actions during this time period to the full extent available under state and federal .” Alaska / Agency Homepage  The Department of Commerce, Community, and Economic Department of Development offices in the Atwood Building and the Juneau Commerce, State Office Building are closed to walk-in traffic but still open Community, and for business and can be contacted via phone or email. Economic Agency Homepage / Alert: Effective  Effective March 15, 2020, all due dates for required reporting Development Emergency Guidance for 03/15/20 to the Division of Banking and Securities are extended 45 Reporting days to reduce regulatory burden during the COVID-19 outbreak. Coronavirus message –  Licensed MLOs may work from home. Updated 3/15/20 NMLS State Agency 04/17/20  All Department personnel are working remotely Operating Status  “Email dbs@alaska as the most timely method of spreadsheet communication. Industry specific email accounts are noted on the State Licensing Requirements page checklists.” NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 60 days: 3

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC o 2020 Q1 Mortgage Call Report o MCR Standard Financial Condition o 2019 Q4 MSB Call Report o 2020 Q1 MSB Call Report o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later Agency homepage 04/03/20  The Division published the following special notice for MLOs: “-Lenders may require Originators (MLOs) to work from home to help prevent the spread of the COVID-19 virus. The Division recognizes that these remote work arrangements are necessary during a state of emergency and will not take administrative or other punitive action against a licensed MLO or the sponsoring licensed company if the MLO conducts activities requiring licensure from home.” Agency Homepage / 04/15/20  “The Alaska Division of Banking and Securities (Division) has COVID-19 Special Notices received several inquiries regarding premium finance companies (PFC) and their that include power of attorney to cancel all policies upon default. The Division does regulate the industry, but does not have authority over the /legal agreement between two entities. We do encourage PFCs to review guidance given and recent bills passed by the federal and state governments related to the COVID-19 crisis to consider flexibility that may be given in regards to late payments during this unprecedented period.” Emergency Regulations 04/20/20 08/18/20  The emergency regulations make changes to the Alaska (effective Administrative Code and include the following: 04/21/20) o 12 AAC 64.063. Minimum education requirements for licensure, is proposed to be changed to give licensees who have completed the required education for initial licensure the needed extension to take their

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC exams and file their applications due to the closure of testing facilities caused by the COVID-19 pandemic. Notice of Adoption of 04/22/20 05/27/20  The notice proposes to make permanent the emergency Emergency Regulation on regulations (12 AAC 64.063), adopted on April 20, 2020. Minimum Education  Comments must be received by 4:30 PM on May 27, 2020. Requirements for Licensure  Written comments may be submitted and must be received at in the Regulations of the least 10 days before the end of the public comment period. Real Commission Agency Homepage 05/26/20  “The Alaska Department of Commerce, Community, and Economic Development (DCCED) and the Alaska Industrial Development and Export Authority (AIDEA) have partnered with Credit Union 1 to offer emergency relief to Alaskan small businesses through the AK CARES Grant Program.”  Information on the Alaska CARES Grant Program is linked here. Alaska / Office of Governor Unveils Path to 04/21/20  Governor Dunleavy announced that the following Governor Mike Reopening Alaskan (effective businesses/industries may reopen as of Friday April 24, 2020, Dunleavy Economy 04/24/20) provided that they follow “rigorous health and safety standards”: o Restaurants (limited dine-in services) o Retail Stores (limited in-store shopping) o Personal Services Businesses – i.e., barbers, nail salons, hairdressers (limited services) o Non-Essential Businesses – i.e., professional business services (limited services) COVID-19 Health Mandate 04/22/20  COVID-19 Health Mandate 016 implements Phase I of 016 (effective Governor Dunleavy’s plan to reopen Alaska by allowing the 04/24/20) following activities and businesses to resume under certain conditions and guidance: non-essentially public facing businesses generally, retail businesses, restaurants dine-n services, personal care services, non-essential non-public facing businesses. 5

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Reopen Alaska Responsibly 05/08/20  Phase 2 of the five-phase Reopen Alaska Responsibly Plan homepage began May 8, 2020.  The plan and a description of each phase is linked here. Reopen Alaska Responsibly 05/19/20  Phase 3 of Alaska’s Reopen Alaska Responsibly Plan begins homepage (effective on May 22, 2020, allowing, in part, for all businesses to 05/22/20) reopen.  General Phase 3/4 guidance is linked here.  Governor Mike Dunleavy’s Phase 3 announcement on May 19, 2020 is linked here. Governor Expands AK 08/20/20  Governor Mike Dunleavy notified the Legislative Budget & CARES Eligibility To Help Audit Committee that he is submitting modifications to the Alaska Small Businesses AK CARES Grant Program to expand the eligibility for applicants.  Currently, applicants for AK CARES grant funding are restricted from applying if they received more than $5,000 in other federal assistance or if the business is a source of secondary income.  The new changes lift the $5,000 restriction, as well as those on secondary income businesses. Other restrictions, such as requiring that businesses must be Alaska based or that businesses cannot have more than 50 employees, remain in place at this time, but may be amended in the future. Declaration of Public Health 11/06/20 12/15/20  The Declaration of Public Health Disaster Emergency, among Disaster Emergency (effective other things, extends the declaration of a state of public health 11/16/20) disaster emergency through December 15, 2020. Arizona / Office of Executive Order: 2020-14 03/24/20 120 days  Temporary delay of enforcement of action orders for the Governor residential premises when one of the following circumstances exist and are documented to the or owner: a. The individual is required to be quarantined based on their diagnosis of COVID-19. b. The individual is ordered by a licensed medical professional to self-quarantine based on their demonstration of symptoms as defined by the Centers 6

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC for Disease Control and Prevention. c. The individual is required to be quarantined based on someone in the home being diagnosed with COVID-19. d. The individual demonstrates that they have a health condition, as defined by the Centers for Disease Control and Prevention, that makes them more at risk for COVID-19 than the average person. e. The individual suffered a substantial loss of income resulting from COVID-19, including: i. Job loss; ii. Reduction in compensation; iii. Closure of place of employment; iv. Obligation to be absent from work to care for a home-bound school-age child; or v. Other pertinent circumstances.” Executive Order 2020-17: 03/26/20  Executive Order 2020-17, applicable to 36 Arizona agencies Continuity of Work (including, for example, the Department of Financial Institutions and the Department of ), requires the following of agencies that individuals or entities: o Defer, by 6 months, license renewal requirements for licenses expiring between March 1, 2020 and September 1, 2020, unless the renewal requirements can be completed online; o Defer, by 6 months, licensee continuing education, unless (i) the renewal requirements can be completed online or (ii) deferral of these requirements is not practical; o “Suspend any rules that prevent or limit the amount of online or alternative learning hours permitted to issue or renew a license”; o “Make every attempt to implement electronic or remote format examinations for licensure where feasible”; and o Issue, unless prohibited by federal law or regulation, a provisional license to applicants who are unable to take the required examination (due to current closure 7

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC of testing centers and unavailability of an electronic/remote testing option) but otherwise satisfy all other requirements for licensure under Arizona statutes and regulations. Note, the provisional license must: (i) be valid for 6 months from the date of issuance, (ii) be suspending 20 days after the in-person testing center reopens or the examinations otherwise become available (e.g., electronic/remote format) unless the applicant passes the examination prior to this date, and (iii) be replaced by a regular license upon successful passage of the required examination.  The Executive Order also authorizes, but does not require, state agencies and boards to waive, at their discretion, any required fees that the state agency or board collects. Executive Order 2020-18: 03/30/20 04/30/20  This Executive Order orders all Arizona individuals to limit Stay Home, Stay Healthy, their time away from home with the following exceptions: “a. Stay Connected To conduct or participate in Essential Activities. b. For employment, to volunteer or participate in Essential Functions. c. To utilize any services or products provided by Essential Businesses. d. Employment, if as a sole proprietor or family owned business, work is conducted in a separate office space from your home and the business is not open to serve the public.”  The Executive Order also provides that “No person shall be required to provide documentation or proof of their activities justify their activities under this order.” Executive Order 2020-21 04/06/20 05/31/20  The Executive Order, in part, orders the temporary Prohibiting Small Business suspension of a commercial eviction action “or any other attempt to inhibit the operations of a business . . . for tenants unable to pay rent due to financial hardship caused by the COVID-19 pandemic.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Executive Order 2020-26 04/08/20 07/01/20  The Executive Order responds to SB 1030, Remote Online Remote Online Notarization (effective Notarization, passed by the Arizona State Legislature in 2019. 04/10/20) The legislation allows “for signers and notaries to meet using the internet and audio-video technology to verify identity” but does not take effect until July 1, 2020.  The Executive Order authorizes Remote Online Notarization “for notarial acts as valid witness to execution of documents,” provided that (i) the procedures outlined in SB 1030 are followed and (ii) all notarization records are “saved and backed up by the notary public in accordance with law.” The Executive Order will be in place until SB 1030 takes effect.  The Executive Order also directs the Secretary of State’s remote online notarization rules to “ensure a secure identity verification process is used through online audio-video and allow the notary and signer to converse in real-time as the signatures and tamper-proof seals are placed on the electronic document.” Executive Order 2020-33: 04/29/220 05/15/20  Executive Order 2020-33 amends the Stay Home, Stay Returning Stronger Healthy, Stay Connected Executive Order (2020-18).  Under the “Stay Home, Stay Healthy, Stay Connected” policy, all individuals, subject to limited exceptions, must “limit their time away from their place of residence or property, except: (a) to conduct or participate in Essential Activities; (b) for employment, to volunteer or participate in Essential Functions; (c) to utilize any services or products provided by Essential Businesses; (d) Employment, if as a sole proprietor or family owned business, work is conducted in a separate office space from your home and the business is not open to serve the public; and (e) no person shall be required to provide documentation or proof of their activities to justify their activities under this order.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Executive Order 2020-36: 05/12/20  Executive Order 2020-36 implements the Arizona “Stay Stay Healthy, Return (effective Healthy, Return Smarter, Return Stronger” policy, rescinding Smarter, Return Stronger 05/16/20) the following expired Executive Orders: 2020-18, 2020-24, 2020-33.  The Executive Order requires that “[a]ny business, whether for- or non-profit, institution, profession or entity that physically operates in this state and servers the public or is an employer shall develop, establish and implement policies based on guidance from the CDC, Department of Labor, Occupational Safety and Health Administration (OSHA) and [the Director of the Arizona Department of Health Services] to limit and mitigate the spread of COVID-19,” which must include specified items (e.g., monitoring for sickness, ensuring physical distancing, providing protective equipment, teleworking when feasible, etc).  The Executive Order will be considered for repeal and revision every two weeks. Executive Order 2020-49: 07/16/20 10/31/20  Executive Order 2020-49 extends the postponement of Continued Postponement of (effective eviction enforcement actions, initially provided for in Eviction Enforcement 07/23/20) Executive Order 2020-14, issued on March 24, 2020, expiring Actions on July 22, 2020. Arizona / Agency Homepage 03/31/20  The Department is open for business but teleworking, Department of available to assist with services through Arizona’s e-licensing Financial system, email, phone, or mail. Institutions Statement on Financial 04/24/20  The guidance responds to Governor Ducey’s direction to state Institutions Working with agencies “to use all the resources necessary to prepare for and Customers Affected by the respond to the outbreak.” Coronavirus; Regulatory  With respect to existing loans, the guidance states that Assistance financial institutions’ “efforts to modify the terms on existing loans for effected customers will not be subject to [the Department’s] criticism” (e.g., restricting debt obligations).

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  With respect to new loans, the guidance states that financial institutions “may also ease terms for new loans to affected borrowers, consistent with prudent banking practices.”  The guidance reassures licensees that the Department will consider the “unusual circumstances” of the COVID-19 emergency when reviewing and responding to each institution’s financial condition. The Department will also “work with affected licensees to reduce burden when scheduling examinations or inspections,” as well providing accommodations to licensees facing difficulty in meeting regulatory reporting requirements (e.g., audited financial statements and related reports). Agency homepage 05/10/20  “Prometric is opening pre-license examination test centers across the US where state and local guidelines allow, and plans on opening most test centers (with reduced capacity) May 31. If you hold a provisional license, you can contact Prometric to make an appointment to take your exam.”  The NMLS Notice Regarding COVID-19 and Prometric Test Center Closures is linked here. Arizona Mortgage Broker Rev. 06/30/20  The Arizona Department of and Financial Company New Application (released Institutions updated its Mortgage Broker New Application Checklist 07/02/20) checklist in NMLS to respond to the unavailability of the mortgage broker examinations caused by the COVID-19 crisis.  The updated checklist implements, pursuant to Executive Order 2020-17 (see above), the “provisional (approved- conditional) licenses available to individuals who meet all license requirements other than passing the mortgage broker exam.” o Among other things, the checklist specifies that the provisional license is effective for 6 months and requires license holders to pass the pre-license

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC examination within 20 days of an email-notification to the provisional licensee that the exam is available. Arizona Mortgage Broker 07/08/20  The Arizona Department of Insurance and Financial Company New Application Institutions revised its most recent update to the AZ Checklist Mortgage Broker New Application checklist in NMLS (see above), which responded to the unavailability of the mortgage broker examinations caused by the COVID-19 crisis.  The revision limits the update, providing for provisional licenses, to sole proprietors only. Arkansas / Interim Regulatory 03/13/20  The Department is currently still at work. However, if Securities Guidance required, they will work from home, and business will Department continue as usual. NMLS COVID-19 Filing 04/01/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; and o the 2020 Q1 MSB Call Report.  The due date for completion of the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later is extended by 60 days. Interim Regulatory Deadline 04/01/20  The guidance responds to the March 27, 2020 change in Guidance NMLS reporting deadline policy.  The Department is providing the following extensions: o Financial statement deadline extension: 60 days o Call report deadline extension: 30 days  Pursuant to the Governor’s March 30, 2020, Executive Order 20-12, all “licensed entities may use real-time audio and visual means to witness the signing of a legal document so long as the identity and physical presence of any and all witnesses and signers in the State of Arkansas are validated at the time of execution of the document by real-time audio or visual 12

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC means. This authorization will expire at the will of Governor Hutchinson or when the state of emergency is terminated.” NMLS State Agency 04/01/20 06/14/20  Only essential Department personnel are working. Operating Status  “Please send licensing questions to [email protected]. spreadsheet General inquires can be sent to [email protected], [email protected], or [email protected]” Temporary Regulatory 04/16/20  The guidance extends the Department’s regulatory relaxation Relaxation for the Duration for the duration of the COVID-19 emergency, whereas of the Emergency previous guidance regarding regulatory relaxation was limited through April 16, 2020.  The guidance states that the position of the Arkansas Securities Commissioner is that “statutes and rules administered by the Commissioner that have specific time constraints be relaxed when it is shown that the need is related to the coronavirus disease 2019.” Extension Of The March 13, 05/22/20 09/01/20  The guidance, addressed to licensed mortgage companies, 2020 Interim Regulatory mortgage loan officers, and branch managers, extends the Guidance For Money interim regulatory guidance (see above), published on March Services Businesses And 13, 2020, which temporarily authorized licensees’ employees Mortgage Companies to work remotely, even if from an unlicensed location.  The interim regulatory guidance is extended through September 1, 2020. Extension Of The March 13, 08/18/20  The guidance, addressed to licensed mortgage companies, 2020 Interim Regulatory mortgage loan officers, and branch managers, extends the Guidance For Money interim regulatory guidance (see above), published on March Services Businesses And 13, 2020, which temporarily authorized licensees’ employees Mortgage Companies to work remotely, even if from an unlicensed location.  The interim regulatory guidance, previously extended through September 1, 2020, is now extended for the duration of the state of emergency, as declared by Governor Hutchinson in Executive Order 20-03.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC California / COVID-19 Industry 05/12/20  The California Department of Public Health and the Official California Guidance: Real Estate California Department of Industrial Relations published State Government Transactions COVID-19 industry guidance for real estate transactions, Website specifically “for businesses operating in the real estate industry including sales and rentals of single-family, multi- family, apartment, commercial, and industrial to support a safe, clean environment for workers.”  The guidance details measures to be taken with respect to (i) establishing written COVID-19 prevention plans, as applied to both the workplace and showing properties, (ii) employee training, (iii) individual control measures and screening, (iv) cleaning and disinfecting protocols for workplaces, (v) cleaning and disinfecting protocols for shown properties, (vi) physical distancing guidelines for workplaces, and (vii) physical distancing guidelines for shown properties. California / State Assembly Bill No. 3088: The 08/31/20  Assembly Bill No. 3088, among other things: Legislature Tenant, Homeowner, and o until January 1, 2023, applies protections against Small Landlord Relief and to “a first mortgage or of trust Stabilization Act of 2020 that is secured by residential that is occupied by a tenant, contains no more than four dwelling units, and meets certain criteria, including that a tenant occupying the property is unable to pay rent due to a reduction in income resulting from the novel coronavirus”; o requires mortgage servicers denying a forbearance request (during the effective time period) to provide the borrower with a written notice stating the reason(s) for denial, provided that the borrower (i) was current on payment as of February 1, 2020 and (ii) is experiencing a financial hardship that prevents the borrower from making timely mortgage payments as a result (directly or indirectly) from the COVID-19 14

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC emergency; Note, mortgage servicers with respect to borrowers of a federally backed mortgage complying with the CARES Act are deemed to be in compliance with this requirement; o until February 1, 2025 imposes certain criteria on the 3 days’ notice provided by to tenants demanding payment of unpaid rent or any other unpaid financial obligation of a tenant that came due during the covered time period; o prohibits an action to recover certain rental debt before March 1, 2021; and o prohibits the eviction of tenants due to nonpayment of rental payments (due between March 1, 2020, and August 31, 2020), provided that the tenant experienced decreased income or increased expenses due to the COVID-19 emergency. California / Office Executive Order N-52-20 04/16/20  Executive Order N-52-20 extends the following deadlines, of the Governor among others, for 60 days: o “The timeframes set forth in Business and Professions Code, Division 4, Part 1, Chapter 3, Article 2 (Section 10150, et seq.) [Real Estate Regulations: Licensees]”; and o “The timeframes set forth in the Business and Professions Code Division 4, Part 1, Chapter 3, Article 2.5 (Section 10170 et seq.) [Real Estate Regulations: Continuing Education], relating to continuing education requirements for real estate licensees, are hereby extended for a period of 60 days.” Executive Order N-69-20 06/15/20  Executive Order N-69-20 extends certain provisions of Executive Order N-52-20 (see above) for an additional 60-days, including the statutory deadlines applicable to DRE licensees.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Executive Order N-71-20 06/30/20 12/30/20  Executive Order N-71-20 modifies Executive Order N-52-20 (see above), including, among other things, extending the following time frames (previously extended by Executive Order N-60-20, see above) until December 31, 2020: o “The timeframes set forth in Business and Professions Code, Division 4, Part 1, Chapter 3, Article 2 (Section 10150, et seq.) [Real Estate Regulations: Licensees]”; and o “The timeframes set forth in the Business and Professions Code Division 4, Part 1, Chapter 3, Article 2.5 (Section 10170 et seq.) [Real Estate Regulations: Continuing Education], relating to continuing education requirements for real estate licensees.” Executive Order N-80-20 09/23/20 03/31/21  Executive Order extends the protections against commercial evictions initially imposed by Executive Order N-28-20, issued on March 16, 2020. The protections are now extended through March 31, 2021. Executive Order N-83-20 10/28/20 06/30/21  Executive Order N-83-20 modifies Executive Order N-71-20 (see above), including, among other things, extending until June 30, 2021 certain fees and continuing education requirements applicable to DRE licensees. California / Guidance to Escrow Agents, 03/21/20  The California Department of Business Oversight “will not Department of Finance Lenders and take enforcement action against licensees for operating Business Servicers, Student Loan unlicensed branches to the extent that, during the state of Oversight (DBO) Servicers, Residential emergency, employees conduct activities from home that Mortgage Lenders and normally would require a branch license, provided that Servicers, and Mortgage appropriate measures are taken to protect consumers and Loan Originators their data.”  “The Department will not criticize student loan servicers or licensees sponsoring mortgage loan originators who permit their respective employees to work from home, provided that: 1. The employee does not keep any physical business records 16

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC at home or anywhere other than the licensed location; 2. The employee does not meet with any customers at home; 3. The licensee has a procedure in place to supervise employees as required by law; 4. The employee uses only computers and devices that are encrypted and accesses the licensee’s network using a virtual private network that is encrypted; and, 5. The licensee and employee take all other necessary measures to protect consumer data privacy. The above also applies to Escrow Law licensees; however, they should be aware that the Department cannot modify any restrictions that may be imposed by the Fidelity Corporation or the licensee’s surety bond.”  “The Commissioner recommends that licensees: o Offer payment accommodations, such as allowing borrowers to defer or skip some payments or extend the payment due date, which would avoid delinquencies and negative credit bureau reporting caused by COVID-19-related disruptions. Mortgage lenders may also ease terms for new loans to affected borrowers, consistent with prudent banking practices, and consult Federal Housing Administration guidance on loss mitigation options. Prudent efforts to modify the terms on existing loans for affected customers will not be subject to examiner criticism by the Department. o Exercise discretion in determining which of their services and transactions are “essential services” for the purposes of “stay-in-place” or “shelter-in-place” orders. o Report to the Department any disruption of services provided to consumers.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  “The Department will not criticize any late mortgage recordation arising from the closure of a county recorder’s office related to COVID-19.”

CA DBO COVID-19 03/25/20  The guidance announces that the following relief is provided Updates by committed financial institutions, including: o 90-day grace period for all mortgage payments – including: . Providing a streamlined process for requesting forbearance for COVID-19-related reasons, supported with available documentation; . Confirmation of approval of and terms of forbearance program; and . Opportunities to extend a forbearance agreement if the consumer continues to experience hardship due to COVID-19; o Relief from fees and charges for 90 days; o No new for 60 days; and o No credit score changes for accessing relief.  The guidance also includes new FAQs on financial relief for consumers. Guidance to Broker-Dealers 03/30/20  The guidance is addressed to broker-dealers and investment and Investment Advisers advisers licensed under the Corporate Securities Law of 1968. (BDIA) During the COVID-  The guidance extends the following filing due dates by 45 19 Pandemic (PDF) days: Notice of Changes by Broker-Dealers and Investment

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Advisers, Form PF for private fund advisers, Annual Report, and Interim Report.  The guidance allows licensees to electronically file Form U4 without a manual signature provided certain conditions are met. NMLS COVID-19 Filing Last updated  The due date for completion of the following reports is Guidance 04/02/20 extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later.  “The DBO CRMLA will allow 30 day extensions only if requested by licensees.” Guidance to Finance 04/03/20  The guidance responds to Executive Order N-28-20’s direction Lenders, PACE to the DBO to work with financial institutions in mitigating Administrators, Deferred COVID-19’s economic impacts. Deposit Originators, and  The guidance addresses, among others, finance lenders and Premium Finance premium finance companies to request (1) that licensees Companies “work with their customers by offering payment plans and extensions at no additional cost to the customer” and (2) “that premium finance companies grant a grace period similar to the grace periods being granted by many insurance companies in order to prevent insureds from experiencing an interruption in insurance coverage.” Consumer financial relief 04/23/20  The California DBO updated their consumer financial relief information and advisories information and advisories to announce the participation of student loan servicers in the financial relief programs. California / COVID-19 FAQs for 03/25/20  In response to the Governor’s shelter-in-place order Department of Licensing Processes and (Executive Order N-33-20, issued March 19, 2020), all DRE Real Estate (DRE) Business Practices offices are closed until further notice. DRE is operational by phone (the DRE public information line will remain open), online, mail (list of addresses), and email. 19

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  Online access includes access to the eLicensing system (to reschedule exams and renew real estate license) and the online complaint system (to file consumer complaints). o eLicensing cannot be used by: (1) officers renewing expired licenses and (2) all restricted licensees; these renewal applications must be submitted via mail.  All licensing exams are cancelled from March 18, 2020 to April 7, 2020. Canceled exams can be rescheduled for free using the eLicensing system.  Continuing education requirements may be completed, for example, online or by mail.  DRE is not, at this time, considering extending expiration dates/deadlines for licensees or waiving fees for late license renewals.  The shelter-in-place order may affect individual live scan service providers. The status of each location will need to be checked individually.  During this time, DRE will accept electronic signatures on licensing documents, but documents with electronic signatures still must be mailed to DRE if it cannot be completed using eLicensing. Alert – Canceled Exams 3/27/20 4/30/20  The DRE is cancelling real estate salesperson and broker through 4/30/20 license exams in all exam centers through April 30, 2020.  Examinees affected by these cancellations will be notified by email and will be allowed to reschedule their canceled exam dates using DRE’s eLicensing system.  Exam rescheduling fees will be waived for canceled exams. Agency Homepage 05/16/20  The DRE announced an extension to the cancelation of real estate salesperson and broker license exams in all exam centers, now canceled through May 16, 2020.  “Examinees affected by these cancellations will be notified by email and will be allowed to reschedule their canceled exam 20

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC dates using DRE’s eLicensing system. Exam rescheduling fees will be waived for canceled exams.” FAQs for Executive Order 04/17/20  The DRE published FAQs to provide information in response N-52-20 to Governor Newsom’s Executive Order N-52-20 (see above).  The FAQs clarify, among other things, that: o Licensees whose license expiration dates are extended by 60 days by Executive Order N-52-20 do not need to request an extension; the DRE is identifying these licenses on their own. o Deadlines for continuing education requirement are extended only for deadlines that fall within the period from April 16, 2020 – June 14, 2020. o The 60-day extension granted by the Executive Order is a one-time extension. o Licensees do not need to use the extension if prepared to meet the original deadlines. o “All licensees are allowed two years beyond the expiration date to renew their license on a late basis. The Executive Order extends the two year grace period for an additional 60 days from the date of the order if the two-year grace period is set to expire between April 16, 2020 and June 14, 2020. o The Executive Order also applies to extending examination application deadlines by 60 days, as well as applying for the salesperson (or broker) license after passing the examination (for which there is a one-year deadline, now extended by 60 days). Agency Homepage 05/14/20 05/31/20  The DRE announced an extension to the cancelation of real estate salesperson and broker license exams in all exam centers, now canceled through May 31, 2020.  Affected examinees will be notified via email and have their rescheduling fee waived. 21

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC FAQs for Executive Order 04/17/20  The DRE published FAQs to provide information in response N-52-20 to Governor Newsom’s Executive Order N-52-20 (see above).  The FAQs clarify, among other things, that: o Licensees whose license expiration dates are extended by 60 days by Executive Order N-52-20 do not need to request an extension; the DRE is identifying these licenses on their own. o Deadlines for continuing education requirement are extended only for deadlines that fall within the period from April 16, 2020 – June 14, 2020. o The 60-day extension granted by the Executive Order is a one-time extension. o Licensees do not need to use the extension if prepared to meet the original deadlines. o “All licensees are allowed two years beyond the expiration date to renew their license on a late basis. The Executive Order extends the two year grace period for an additional 60 days from the date of the order if the two-year grace period is set to expire between April 16, 2020 and June 14, 2020. o The Executive Order also applies to extending examination application deadlines by 60 days, as well as applying for the salesperson (or broker) license after passing the examination (for which there is a one-year deadline, now extended by 60 days). FAQs for Executive Orders Rev. 06/16/20  The DRE published FAQs to provide information in response N-52-20 and N-69-20 to Governor Newsom’s Executive Order N-69-20 (see above), which extended the 60-day extensions granted in Executive Order N-52-20 (see above).  The FAQs are revised to clarify that licensees whose license expired during the 60-day period between April 16, 2020 and June 14, 2020 have been granted, under Executive Order N-69- 22

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC 20, an additional 60-day extension to submit renewal applications, fees, and continuing education requirements.  The revised FAQs have also (i) adjusted the relevant time periods to reflect the new date range for this second extension: June 15, 2020 and August 14, 2020; and (ii) include a newly added chart describing the timeframes/deadlines with respect to the extensions under each EO N-52-20 as EO- 69-20, as well as a combined total. News Release: Governor 07/14/20  The DRE news release highlights the June 30, 2020 Executive Newsom Issues Executive Order N-71-20 (see above), emphasizing the following Order Impacting DRE extensions to December 31, 2020: Applicants and Licensees o “timeframes associated with examination application expiration dates o timeframes associated with license expiration dates o deadlines related to the payment of license application fees o deadlines related to the payment of license renewal fees o deadlines related to completing continuing education requirements for expiring licensees o deadlines specified in existing Orders issued by the Real Estate Commissioner” FAQs for Executive Orders Rev. 07/16/20  The California DRE revised and updated its FAQs for certain N-52-20, N-69-20 and N-71- executive orders (see above) to include the Executive Order N- 20 Impacting Applicants 71-20 issued on June 30, 2020 (see above). and Licensees  The revisions to the FAQs include, among other things an extension to submit renewal applications, fees, and continuing education, granted until December 13, 2020, for: o licenses expired between April 16, 2020 and June 14, 2020 (identified in Executive Order N-52-20); o licenses expired between June 15, 2020 and August 14, 2020 (identified in Executive Order N-69-20); and 23

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC o licenses expired between August 15, 2020 and December 30, 2020 (identified in Executive Order N- 69-20).  The revised FAQs also provide that: o Licensees who are subject to the above extensions must still complete the continuing education requirements unless the licensee is exempt due to the 70/30 exemption. o “Examination applications are valid for a two-year period from the date of receipt. Per Executive Order N-71-20, if your examination application expires between April 16, 2020 and December 30, 2020, your application is valid through December 31, 2020.” o “Per Executive Order N-71-20, if your deadline to apply for a real estate license after passing the examination is between April 16, 2020 and December 30, 2020, your period to apply for the license is extended until December 31, 2020.” COVID-19 FAQs for Rev. 09/21/20  The DRE updated its FAQs for licensing processes, initially Licensing Processes published on March 25, 2020 (see above). The revisions to the FAQs address, among other things: o the reopening of all DRE offices to the public and the health/safety procedures in place (e.g., social distancing, additional cleaning, mandatory face masks); o exam cancellation announcements and the (free) rescheduling process; o license renewals via the paperless eLicensing online system; o the impact of shelter-in-place orders on the (mandatory) Live Scan services; and

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC o the extent to which the DRE will accept electronic signatures (i.e., electronic signatures may be used but the documents with electronic signatures must still be mailed to DRE if not completed using eLicensing); Colorado / Office Executive Order D 2020 017 03/25/20 04/11/20  Executive Order D 2020 017 orders Coloradans to stay at of the Governor (effective home, subject to limited exceptions, due to the presence of 03/26/20) COVID-19 in the state. Additionally, the Executive Order orders all non-critical businesses “to close temporarily except as necessary to engage in minimum basic operations needed to protect assets and maintain personnel functions.” Executive Order D 2020-024 04/06/20 04/26/20  Executive Order D 2020 024 amends and extends Executive Order D 2020 017 ‘s stay-at-home order. Executive Order D 2020-029: 04/06/20 04/30/20  Executive Order D 2020-029 extends and amends Executive Amending and Extending Order 2020 011, which temporarily suspended certain Executive Order D 2020 011 regulatory statutes in response to the COVID-19 emergency. Ordering the Temporary  The amendments, among others, include a temporary Suspension of Certain suspension of the fingerprint-based background check duties Regulatory Statutes Due to of the Colorado Bureau of Investigations (CBI). The purpose the Presence of COVID-19 of the temporary suspension is to provide CBI with additional time to complete their duties. Executive Order D 2020 044 04/26/20 05/27/20  Executive Order D 2020 044 replaces the stay-at-home orders (effective with a safer-at-home program, including, for example, 04/27/20) phased-in-changes allowing for certain businesses to reopen. Executive Order D 2020-052: 04/30/20 05/30/20  Executive Order D 2020 052 extends Executive Order 2020 Extending Executive Orders 011, as amended by Executive Order D 2020-029 (see above), D 2020 011 and D 2020 029 for 30 days. Concerning the Temporary Suspension of Certain Regulatory Statutes Due to the Presence of COVID-19

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Colorado / Guidance on the Safer at 04/27/20  The guidance responds to Executive Order D 2020 044, Department of Home Order replacing the stay-at-home order with a safer-at-home Regulatory program. Agencies  “All individuals are encouraged to stay at home as much as possible and practice social distancing to reduce the likelihood of disease transmission. Certain restrictions remain in place concerning limitations on activities, travel, and public gatherings. Workplace restrictions remain necessary while steps are taken to implement standard social distancing requirements, cleaning standards, and other items necessary to reduce the possibility of disease spread.”  The guidance directs readers to the Safer at Home FAQs for more information, linked here. Colorado / Division Advisory  “An MLO is able to perform their mortgage related activities Department of at a location other than at their registered license location.” Regulatory NMLS State Agency 04/10/20  All Colorado DRE personnel are working remotely. Agencies / Operating Status (effective  COVID-19 specific contact information: Division of Real spreadsheet 04/01/20) [email protected] Estate NMLS COVID-19 Filing 04/10/20  The due date for completion of the following reports is Guidance extended by 30 days: o 2020 Q1 Mortgage Call Report o MCR Standard Financial Condition o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later Real Estate Brokers & 05/08/20  The guidance clarifies and synthesizes guidance for real estate Services - Safer at Home brokers and services as it relates to Colorado’s new Safer at Guidance and FAQ Home phase of the COVID-19 pandemic, as implemented by Executive Order D 2020 044 and Public Health Order 20-28.  The guidance clarifies that marketing services and showings are permissible, subject to restrictions, unless the licensee’s county is still under a Stay At Home Order.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  The guidance provides a “do’s and don’ts” matrix for field services and real estate.  The FAQs address, among other things: (i) whether a brokerage firm can reopen offices and what obligations are imposed upon reopening, (ii) reconciling various requirements by following the most restrictive terms, (iii) the requirement to have written COVID-19 policies in place, (iv) the requirements for showings (e.g., disinfecting, providing personal protective equipment, etc), and (v) the procedures and requirements for showing property. Colorado / Safer At Home webpage 04/27/20  In response to Executive Order D 2020 044, replacing the stay- Department of at-home order with a safer-at-home program, Colorado Public Health & launched a “Safer at Home” website. Environment  Under the safer-at-home program, “Coloradans are no longer ordered to stay home, but are strongly advised to stay at home. Critical businesses are open and non-critical businesses are operating with restrictions.” Fifth Amended Public 06/02/20  Fifth Amended Public Health Order 20-28 supersedes and Health Order 20-28: Safer at (effective replaces Public Health Orders 20-22 and 20-24. Home and in The Vast, 06/01/20)  The Order, among other things, provides guidance to critical Great Outdoors businesses, defined to include, among other businesses, the following “financial and professional institutions”: o and credit unions; o Insurance and payroll; o Services related to financial markets; and o Professional services, such as legal, companies, or accounting services, real estate appraisals and transactions. Connecticut / Mortgage Relief During 03/31/20  Governor Lamont reached an agreement with Connecticut Office of the COVID-19 Pandemic credit unions and banks to provide residential mortgage relief Governor to alleviate hardship caused by the COVID-19 crisis. The

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC following relief policies are offered by the participants under the agreement: o 90-day grace period for all mortgage payments; o Relief from fees and charges for 90 days; o No new foreclosures for 60 days; and o No credit score changes for accessing relief. Governor Lamont Provides 06/04/20 07/30/20  The Connecticut Mortgage Relief Program (see above), in Update on Connecticut’s which over 45 banks and credit unions voluntarily participate, Coronavirus Response has been extended. Efforts: Governor Lamont  The program, launched March 31, 2020, includes consumer and Banking Commissioner relief efforts (e.g., grace period for all mortgage payments, Perez announce 60-day waived fees, no new foreclosures, no credit score changes for extension to mortgage relief accessing relief) was set to expire on May 31, 2020. The program program will now run through July 30, 2020. Executive Order No. 7GGG 7/13/20  Executive Order No. 7GGG authorizes “the Chief Executive Officer of the Connecticut Housing Finance Authority (CHFA) to modify or waive requirements of those statutes, known as the Emergency Mortgage Assistance Program (“EMAP”), only to the extent necessary to create and administer a temporary program of mortgage assistance for borrowers who meet certain criteria to be established by Commissioner of the Department of Housing, in consultation with the Secretary of the Office of Policy and Management and Office of the Governor, to mitigate the effects of the COVID-19 pandemic and thereby prevent homelessness.” o This provision of the Executive Order is effective for six months from the date of this order. Executive Order No. 9A: 09/08/20 11/09/20  Executive Order No. 9A reissues “all executive orders issued Protection of Public Health pursuant to the public health and civil preparedness and Safety During COVID- emergencies declared on March 10, 2020 and renewed on 19 Pandemic – Extension of September 1, 2020 (COVID-19 Orders) that are unexpired and Covid-19 Executive Orders currently in effect.” 28

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  However, the Executive Order also specifies that “[a]ny unexpired, reissued COVID-19 Order or individual section of any such order that is scheduled to expire on any other specific date shall remain in effect until such specific date,” including, for example, the October 1, 2020 expiration date of the eviction moratorium (which will remain unchanged and unaffected by Executive Order No. 9A). Governor Lamont 11/4/2020  Governor Ned Lamont and Connecticut Housing Announces Reopening of Commissioner Seila Mosquera-Bruno announced that the Residential Renters State of Connecticut is opening a second round of funding Assistance Program Amid under the Temporary Rental Housing Assistance Program COVID-19 Pandemic (TRHAP) to applicants seeking assistance with residential rent payments delayed by financial stress related to the ongoing COVID-19 pandemic. In this round, the program will for the first time accept applications directly from small landlords. Connecticut / Sector Rules and 05/08/20  In preparation for the Connecticut May 20, 2020 reopening Department of Certification for May 20th date, Connecticut released guidelines for individual sectors Economic and Reopen: Offices reopening, including offices. Although permitted to reopen Community on May 20, 2020, subject to certain conditions, the guidance Development encourages office employees to continue to work from home if possible.  Please note, businesses must self-certify prior to reopening. The certification system is linked here. Phase 2 Reopen Rules by 05/06/20  Connecticut released sector-specific rules for Phase 2 of Sector (effective Connecticut’s reopening plan, beginning on June 17, 2020. 06/17/20) Connecticut / Agency Homepage  “The Department of Banking has closed its offices to the Department of public. However, agency staff will continue to provide Banking services to consumers and industry through telework.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  Electronic communication should be used to contact the Department, but agency staff will continue to check voicemails. NMLS State Agency 03/17/20 04/17/20  All Department personnel is working remotely. Operating Status  All questions should be sent to the following email: spreadsheet [email protected]. Mortgage Servicer Guidance 03/18/20  The guidance encourages mortgage servicers “to work with all borrowers (particularly individuals associated with industries more susceptible to volatility) whose ability to make loan repayments at this time may be impacted by COVID-19.” Efforts include, for example, “waiving late fees, offering forbearance plans or other deferment options and having adequate staff available to proactively work with borrowers facing hardship as a result of the COVID-19 outbreak.” Extended Deadlines for Call 04/02/20  The Department of Banking will take a no action position on Reports and Financial the original filing deadlines for call reports and financial Statement Filings for statement filings in an effort to provide flexibility with Consumer Credit Licensees administrative burdens. o MSB Q4 2019: extended from 3/31/20 to 4/30/20 o MCR Q1 2020: extended from 5/15/20 to 6/14/20 o MSB Q1 2020: extended from 5/15/20 to 6/14/20 o MCR Standard Financial Condition: extended from 90 days from end of the company’s fiscal year to 120 days from the end of the company’s fiscal year  Financial Statement: extended from 90 days from end of the company’s fiscal year to 120 days from the end of the company’s fiscal year. NMLS COVID-19 Filing 04/02/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; 30

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later;  “Based on a recommendation from the NMLS Policy Committee, the CT Department of Banking will not take action if Call Reports and Annual Financial Statements are filed within 30 days of the placement of the License Item in NMLS. Please review the chart available on NMLS for the specific dates these items are due.” Agency Homepage 04/12/20  “All previously enacted executive orders on all closures, distancing, and safety measures have been extended through at least May 20.” Revised Memorandum: No 04/16/20 05/31/20  The Revised Memorandum is addressed to, among licensees, Action Position Regarding all Connecticut Mortgage Lender, Mortgage Correspondent Temporarily Working from Lender, Mortgage Broker, Mortgage Loan Originator, Loan Home Due to COVID-19 Processor or Underwriter, and Student Loan Servicer Licensees.  “On March 9, 2020, the Banking Commissioner issued a no action position to address branch licensing issues in light of temporary mitigation actions licensees needed to take to continue business in light of COVID-19. This revised memorandum reiterates the original no action position and extends the no action position through May 31, 2020.”  The March 9, 2020, no action position memorandum is linked here. Memo to Financial 04/16/20  The memo responds to the federal government’s issuance of Institutions Regarding stimulus payments to consumers for COVID-19 financial Access to Stimulus Funds relief.  “Connecticut financial institutions are strongly urged to not use a stimulus payment to satisfy an overdraft that existed prior to a stimulus payment being deposited to the account, 31

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC or to exercise rights of offset against the account with respect to other debts, for 30 days from the date the stimulus payment is deposited to the account, without express agreement of the customer or member. If a financial institution’s systems automatically apply a stimulus payment to an account overdraft, the financial institution is urged to reverse the application of the stimulus payment as promptly as possible.” Agency COVID-19 resource 05/01/20 05/20/20  “Connecticut's ‘Stay Safe, Stay Home’ and all other related page safety measures remain in effect through at least May 20. All nonessential workers are directed to work from home, and social and recreational gatherings of more than five are prohibited.” Agency COVID-19 resource 05/18/20  In preparation for the Connecticut May 20, 2020 reopening page date, the DOB removed its reminder that “Connecticut's ‘Stay Safe, Stay Home’ and all other related safety measures remain in effect through at least May 20,” replacing this message with a reminder that “Connecticut residents are urged to continue taking precautions to prevent the spread of COVID-19.” Revised 05/20/20 06/30/20  The Revised Memorandum is addressed to, among other Memorandum: No Action licensees, all Connecticut Mortgage Lender, Mortgage Position Regarding Correspondent Lender, Mortgage Broker, Mortgage Loan Temporarily Working from Originator, Loan Processor or Underwriter, and Student Loan Home Due to COVID-19 Servicer Licensees.  The Revised Memorandum reiterates and extends the no action position memorandum, addressing branch licensing issues in light of COVID-19, originally issued on March 9, 2020 and previously extended through May 31, 2020 on April 16, 2020 (see above).  The Revised Memorandum extends the no action position through June 30, 2020.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  The March 9, 2020 no action position memorandum is linked here. Revised 06/19/20 08/31/20  The Revised Memorandum is addressed to, among other Memorandum: No Action licensees, all Connecticut Mortgage Lender, Mortgage Position Regarding Correspondent Lender, Mortgage Broker, Mortgage Loan Temporarily Working from Originator, Loan Processor or Underwriter, and Student Loan Home Due to COVID-19 Servicer Licensees.  The Revised Memorandum reiterates and extends the no action position memorandum, addressing branch licensing issues in light of COVID-19, originally issued on March 9, 2020 and previously extended through June 30, 2020 (see above).  The Revised Memorandum extends the no action position through August 31, 2020. Revised 08/21/20 12/31/20  The Revised Memorandum is addressed to, among other Memorandum: No Action licensees, all Connecticut Mortgage Lender, Mortgage Position Regarding Correspondent Lender, Mortgage Broker, Mortgage Loan Temporarily Working from Originator, Loan Processor or Underwriter, and Student Loan Home Due to COVID-19 Servicer Licensees.  The Revised Memorandum reiterates and extends the no action position memorandum, addressing branch licensing issues in light of COVID-19, originally issued on March 9, 2020 and previously extended through August 31, 2020 (see above).  The Revised Memorandum extends the no action position through December 31, 2020. Delaware / Office Informal regulator guidance  The Delaware Office of the State Commissioner are still of the State Bank working at the office and processing of applications has not Commissioner changed. District of D.C. Act 23-286: COVID-19 04/10/20 07/09/20  The COVID-19 Response Supplemental Emergency Columbia / Response Supplemental Amendment Act of 2020, in part, provides for mortgage relief Council of the (under Section 202), which provides that during a public 33

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC District of Emergency Amendment Act health emergency declared by the Mayor and for 60 days Columbia of 2020 thereafter, “a mortgage servicer that holds mortgage servicing rights to a residential mortgage loan or loan under the jurisdiction of the Commissioner of the Department of Insurance, Securities, and Banking, shall develop a deferment program for borrowers” that meets certain minimum qualifications.  The deferment program, must, at a minimum: (1) grant at least a 90-day deferment period of mortgage payments; (2) waive any fees (e.g., late fees, processing fees) accrued during the public health emergency; and (3) not include reporting any derogatory information (e.g., delinquency) resulting from the deferral to a credit bureau.  Section 202 also provides, among other things, requirements for application criteria, application procedures, and record keeping, in addition to specifying appeal procedures and applicability to rental properties. D.C. Act 23-299: COVID-19 05/04/20  The COVID-19 Supplemental Corrections Emergency Supplemental Corrections Amendment Act of 2020 includes amendments to the COVID- Emergency Amendment Act 19 Response Supplemental Emergency Amendment Act of of 2020 2020 (see above).  The Act amends, among other sections, Section 202 (providing mortgage relief) to, among other changes: o Expand the covered entities to “mortgage lenders” (defined to include mortgage servicers), in place of “mortgage servicers.” o Specify that the 90-day deferment applies to the monthly payment of principal and interest on a mortgage. o Require that a “mortgage lender who approves an application for deferment pursuant to this section shall, on or before May 8, 2020, provide to the 34

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC Commissioner, notice of all approved applications on a form prescribed by the Commissioner and such notice shall include the percentage of mortgage deferment approved for and accepted by each borrower.” o Require that “[a]fter the initial submission prescribed in this paragraph, a mortgage lender who approved an application for deferment pursuant to this section shall provide the Commissioner with a list of all new approvals in 15-day intervals for the duration of the public health emergency and for 60 days thereafter.”  The Act, effective immediately, will remain in effect for no longer than 90 days. District of Agency homepage  The DC Department of Insurance, Securities, and Banking “is Columbia / currently conducting business via telework and will not be Department of able to address consumer issues in person.” Insurance, NMLS State Agency 04/20/20 05/15/20  The Department extended the end date for all personnel’s Securities and Operating Status remote work from 03/16/20 to 05/15/20. Banking spreadsheet NMLS COVID-19 Filing 04/20/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later due to COVID-19. FAQs and Guidance: 05/04/20  The District of Columbia Department of Insurance, Securities Residential Mortgage and and Banking released FAQs and guidance regarding the Commercial Mortgage residential mortgage and commercial mortgage deferment Deferment Program program under Section 202 of the District’s COVID-19 Response Supplemental Emergency Amendment Act of 2020 (see Council of the District of Columbia).

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC  The FAQs address the scope of “mortgage lenders” under the Act, clarifying that because the Act waives the exemptions provided for in Section 3 of the Mortgage Lender and Broker Act of 1996, the definition under the Act is expanded to include any entity, subject to exemptions, servicing a residential or commercial mortgage loan for real property located in the District of Columbia. o The exemptions exclude the following from the definition of a mortgage lender: the Federal Home Loan Mortgage Corporation, the Federal National Mortgage Association, and the Government National Mortgage Association.  The FAQs specify two submissions due to the Department of Insurance, Securities and Banking (via : [email protected]) no later than May 8, 2020: (i) the deferment program application criteria and procedures for borrowers to apply either online or by telephone, and (ii) an initial report (i.e, the Mortgage Deferment Status Report), which must be updated in 15 day intervals for the duration of the public health emergency and 60 days thereafter. The FAQs also specify the required application criteria and contents of the Mortgage Deferment Status Report.  The FAQs also address, among other things, (i) a prohibition on requiring lump sum payments under the deferment program, (ii) accommodations to a borrower’s tenants, and record-keeping and compliance. District of Stay Home DC 03/30/20  Mayor Bowser issued a stay-at-home order for DC, Columbia / Office (effective reinforcing the Mayor’s previous direction to forgo all non- of Mayor Muriel 04/01/20) essential activities and stay home. Bowser  “The Mayor’s Order specifies that residents may only leave their residences to: engage in essential activities, including obtaining medical care that cannot be provided through 36

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner BrodskyEffective) Kider PC telehealth and obtaining food and essential household goods; perform or access essential governmental functions; work at essential businesses; engage in essential travel; or engage in allowable recreational activities, as defined by the Mayor’s Order.”  Penalties for willful violation of the order include a fine up to $5,000 and/or imprisonment for up to 90 days. Mayor’s Order 2020-063 04/15/2 05/15/20  Mayor’s Order 2020-063, among other things, extends the (effective declared public emergency and public health emergency 04/17/20) through May 15, 2020. Mayor’s Order 2020-066 05/13/20 06/08/20  Mayor’s Order 2020-066, among other things, extends the (effective public emergency and public health emergency through June 05/16/20) 8, 2020. Mayor's Order 2020-067: 05/27/20 07/24/20  Mayor’s Order 2020-067 lifts the stay-at-home order and Phase One of Washington, (effective implements phase one of DC’s reopening plan. DC Reopening 05/29/20)  The Mayor’s Order also extends the public emergency and public health emergency to July 24, 2020. Florida / Office of NMLS State Agency 03/17/20  All Florida Office of Financial Regulation personnel are Financial Operating Status working remotely. Regulation spreadsheet Emergency Order 2020-02 03/26/2020  “For the holder of any license issued by the Office under Chapters 494 and 560, Florida Statutes, with an annual financial condition report or financial statement filing deadline occurring in the month of March or April, 2020, the existing deadline is suspended and tolled for a period of 45 days from the existing filing deadline, unless extended by subsequent order.” NMLS COVID-19 Filing 04/20/20  The due date for completion of the MCR Standard Financial Guidance Condition is extended by 45 days. Emergency Order 2020-04 06/26/20  With respect to the Division of Consumer Finance, the Emergency Order extends certain filing deadlines for mortgage brokers and lenders, among other licensees. For 37

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) mortgage brokers and lenders with “a mortgage call report (including the expanded call report and residential mortgage loan activity component) filing deadline occurring in the month of May 2020, the existing deadline is suspended and tolled for a period of 30 days from the existing filing deadline, unless extended by subsequent order.” Florida / Office of Executive Order No. 20-94 04/02/20 05/17/20  Executive Order No. 20-94 suspends and tolls any statute the Governor providing for either: (i) “a mortgage foreclosure cause of action under Florida law for 45 days from the date of this Executive Order, including any extensions”; or (ii) “an Brodsky eviction cause of action under Florida law solely as it relates to non-payment of rent by residential tenants due to the COVID-19 emergency for 45 days from the date of this Executive Order., including any extensions.” Executive Order No. 20-112: 04/29/20  Executive Order No. 20-112 implements the first phase in re- Phase 1 Safe. Smart. Step- (effective opening Florida’s economy, allowing for the reopening of by-Step. Plan for Florida's 05/04/20) certain businesses, subject to social distancing requirements. Recovery Executive Order No. 2020- 05/08/20 07/07/20  Executive Order No. 2020-114 extends the state of emergency, 114: Emergency declared in Executive Order 20-52, for 60 days from the Management – Extension of issuance of Executive Order No. 2020-114. Executive Order 20-52 – COVID-19 Kider Executive Order No. 20-121: 05/14/20 06/02/20  Executive Order No. 121 extends Executive Order 20-94 (see Limited Extension of above) until June 2, 2020. Mortgage Foreclosure and Eviction Relief Executive Order No. 20-137 06/01/20 07/01/20  Executive Order No. 20-137 extends Executive Order-94 (see above), which was previously extended by Executive Order No. 20-121 (see above).  Executive Order-94 is extendedPC until July 1, 2020.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order No. 20-139: 06/03/20  Executive Order No. 20-139 implements Phase 2 of Florida’ Phase 2: Safe. Smart. Step- (effective recovery plan. by-Step. Plan for Florida's 06/05/20) Recovery Executive Order Number 06/30/20 08/01/20  Executive Order 20-159 extends Executive Order 20-94 (see 20-159: Limited Extension of above), expiring on July 1, 2020 as extended by Executive Mortgage Foreclosure and Orders 20-121 and 20-137, until August 1, 2020. Eviction Relief Executive Order Number 07/07/20 09/05/20  Executive Order No. 2020-166 extends the state of emergency, 20-166: Emergency declared in Executive Order 20-52 and previously extended Management-Extension of Brodsky by Executive Order No. 2020-114. Executive Order 20-52-  Executive Order No. 2020-166 extends the state of emergency COVID-19 for 60 days from the issuance of Executive Order No. 2020- 166. Executive Order Number 07/29/20  Executive Order 20-180 revises and extends Executive Order 20-180: Limited Extension of 20-94 (see above), which provides “mortgage foreclosure and Mortgage Foreclosure and eviction relief . . . to single-family mortgagors and residential Eviction Relief tenants adversely affected by the COVID-19 emergency” and otherwise would expire on August 1, 2020. o Executive Order 20-180 amends Executive Order 20-94 to (i) “suspend and toll any statute providing for final action at the conclusion of a mortgage foreclosure Kiderproceeding under Florida law solely when the proceeding arises from nonpayment of mortgage by a single-family mortgagor adversely affected by the COVID-19 emergency”; (ii) “suspend and toll any statute providing for final action at the conclusion of an eviction proceeding under Florida law solely when the proceeding arises from non-payment of rent by a residential tenant adversely affected by the COVID-19 emergency”; (iii) providePC a definition for “adversely affected by the COVID-1 9 emergency”; and (iv) state 39

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) that the executive order may not be construed to suspend or otherwise affect “foreclosure proceedings unrelated to non-payment of mortgage” or an “eviction proceeding under Florida law solely when the proceeding arises from non-payment of rent.” o Executive Order 20-180 extends Executive Order 20-94 until September 1, 2020. Executive Order Number 08/31/2020 10/01/20  Executive Order No. 20-211 extends Executive Order 20-180 20-211 (see above) until October 1, 2020, thereby extending the mortgage foreclosure and eviction relief to single-family Brodsky mortgagors and residential tenants adversely affected by the COVID-19 emergency. Executive Order 2020-213 09/04/20 11/03/20  Executive Order No. 2020-166 extends the state of emergency, initially declared in Executive Order 20-52, for 60 days. Executive Order 2020-276 11/03/20 01/02/21  Executive Order No. 2020-276 extends the state of emergency, initially declared in Executive Order 20-52, for 60 days. Georgia / Informal regulator guidance  Georgia Department of Banking and Finance Examiners are Department of working remotely. They still have the ability to process Banking and applications on a normal basis and do not anticipate any Finance delays. NMLS State Agency 03/13/20  There is limited staff in the Department’s main office, and Operating Status other personnel are working remotely. spreadsheet Kider NMLS COVID-19 Filing 04/02/20  The Department “does not intend on taking administrative Guidance action or issuing a fine for reports filed within the 30 days.” Agency homepage 04/03/20  “[T]he Department is implementing electronic document submission for correspondence. Regular and ongoing correspondence should be submitted to the designated Department recipient through email.” NMLS State Agency Last updated  Limited Georgia Department of Banking and Finance staff are Operating Status 04/06/20 working in the main office.PC All other Department personnel spreadsheet are working remotely. 40

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) (effective  General questions should be emailed at the following: 03/13/20) o Mortgage at [email protected] and o MSBs at [email protected]  “In order to improve our service, the Department is implementing electronic document submission for correspondence. Regular and ongoing correspondence should be submitted to the designated Department recipient through email.” Georgia / Office of Gov. Kemp Updates 04/20/20  Governor Kemp made two announcements with regard to the Governor Georgians on COVID-19 (effective reopening businesses: Brodsky04/24/20) o First, as of Friday, April 24, 2020, the following businesses may reopen: gyms, fitness centers, bowling alleys, body art studios, barbers, cosmetologists, hair designers, nail care artists, estheticians, their respective schools, and massage therapists. o Second, “[s]ubject to specific social distancing and sanitation mandates, theaters, private social clubs, and restaurant dine-in services will be allowed to reopen on Monday, April 27.”  Governor Kemp reiterated that the shelter-in-place order will, for most Georgians, expire at 11:59 PM on April 30. Executive Order: Renewal of 04/30/20 06/12/20  The Executive Order renews the Public Health State of Public Health State of Emergency,Kider issued on March 14, 2020 and previously Emergency renewed on April 8, 2020.  The Public Health State of Emergency is extended through June 12, 2020. Executive Order 05.28.20.01: 05/28/20 07/12/20  Executive Order 05.28.20.01 extends the Public Health State of Renewal of Public Health Emergency through July 12, 2020. State of Emergency Executive Order 06.29.20: 06/29/20 08/11/20  The Executive Order extends the Public Health State of Renewal of Public Health Emergency, otherwise setPC to expire on July 12, 2020 under State of Emergency 41

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order 05.28.01 (see above), for an additional 30 days, through August 11, 2020. Executive Order 07.13.20 07/13/20 07/27/20  Executive Order 07.13.20 adopts the terms of and extends Executive Order 07.06.20, which declared a state of emergency to expire on July 13, 2020.  Under Executive Order 07.13.20, the state of emergency is extended through July 27, 2020. Executive Order 07.31.20.01: 07/31/20 09/10/20  Executive Order 07.31.20.01 extends the Public Health State of Renewal of Public Health Emergency, otherwise set to expire on August 11, 2020 under State of Emergency Executive Order 05.28.01 (see above), for an additional 30 days, Brodsky through September 10, 2020. Executive Order 07.31.20.02: 07/31/20  Executive Order 07.31.20.02 implements and authorizes Providing additional certain precautions to combat COVID-19. guidance for Empowering a  Among other things, the Executive Order: Healthy Georgia in response o authorizes the Georgia Department of Economic to COVID-19 Development “to issue guidance to any business, corporation, organization, or industry trade group regarding its status as Critical Infrastructure.” Such guidance must be in writing but need not be supported by a finding of fact. o requires businesses, establishments, corporations, and organizations (whether or not “Critical KiderInfrastructure”) to implement measures mitigating the exposure and spread of COVID-19 if continuing in- person operations during the Executive Order. Certain practices are listed as examples (and some, recommendations) but no specific practices are mandated. Executive Order 08.31.20.01: 08/31/20 010/10/20  Executive Order 08.31.20.01 extends the Public Health State of Renewal of Public Health Emergency, otherwise set to expire on September 10, 2020 State of Emergency under Executive Order 05.28.01PC (see above), for an additional 30 days—i.e., through October 10, 2020. 42

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order 10.30.20.01: 10/30/20 12/09/20  Executive Order 08.31.20.01 extends the Public Health State of Renewal of Public Health Emergency, otherwise set to expire on November 9, 2020 State of Emergency under Executive Order 05.28.01 (see above), for an additional 30 days—i.e., through December 9, 2020. Hawaii / Agency homepage  “Due to COVID-19 and for the health and safety of Department of consumers, the Department of Commerce and Consumer Commerce and Affairs offices will be closed to the public through Thursday, Consumer Affairs April 30th or until further notice. During this period of office / Division of closure, no walk-in services will be available and the public is Financial strongly encouraged to use our online services.” Institutions Interim Regulatory Brodsky03/17/20 06/30/20  The guidance states the intent of the Hawaii Division of Guidance – Reduction in Financial Institutions (DFI) is “to temporarily allow Branch Office Hours Companies licensed by DFI with physical locations in the State of Hawaii to reduce office hours or temporarily close offices during this Emergency Period.”  Pursuant to statutory authority, financial institutions may “temporarily close or relocate a branch or agency office in the event of an emergency or for other good cause.” The guidance states that in the event of temporary closure or relocation, notice must be provided to the Commissioner and to the institution’s customers. The guidance also recognizes a reduction in branch hours as a temporary closure.  TheKider guidance reiterates that because Hawaii statutes do “not restrict a licensed MLO from working at locations necessary to conduct lawful business,” this practice may continue, provided that the location is not held out as a branch office of the mortgage loan originator company.  If a branch of a mortgage loan company “will not be opened during normal business hours, the Branch Manager must post signage at the branch office indicating the temporary closure of the branch and a methodPC by which a consumer may contact the Branch Manager.” 43

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  DFI requests a courtesy notification be made to DFI if a branch will be temporarily closed (including a branch reducing its normal business hours).  The guidance also addresses escrow depository and money transmitters. NMLS State Agency 03/20/20 04/03/20  The Department has stated that email is the best and Operating Status preferred method of contact. spreadsheet NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: Brodsky o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Agency Homepage 04/28/20  The Department of Commerce and Consumer Affairs extended their office closures through May 31. Agency Homepage 05/26/20  “Due to COVID-19 and for the health and safety of both consumers and staff, walk-in services at the Department of Commerce and Consumer Affairs offices are unavailable to the public through Sunday, May 31st. During this period, staff continue to telework and remain available to meet the needs of the public over the phone and online.”  “WalkKider-in service will resume on June 1, with abbreviated hours from 7:45 a.m. to 12 p.m., Monday through Friday. The public is strongly encouraged to continue calling in or utilizing online services at this time.” Interim Regulatory Rev. 08/13/20 09/30/20  The guidance extends the authorization for DFI licensees with Guidance – Reduction in physical locations in Hawaii to reduce office hours or Branch Office Hours temporarily close. Supplemental Guidance  The guidance, initially published on March 17, 2020 (see above) and last extended to July 31,PC is now extended to September 30, 2020. 44

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Idaho / Temporary Regulatory 03/12/20 06/30/20  Licensees, registrants, and their employees may work from Department of Guidance Regarding home, provided that licensable activities conducted from the Finance Working from Home Due to residence meet certain requirements: “1. Data Coronavirus/COVID-19 requirements include provisions for the employee to access Concerns or Quarantines the company’s secure origination system from any out-of- office device the MLO uses through the use of a VPN or other system that requires passwords or an identification authentication. The company is responsible to maintain any updates or other requirements in order to keep information and devices secure; 2. Neither the employee nor the company Brodsky is to do any act that would indicate or tend to indicate that the employee is conducting business from an unlicensed location. Such acts include but are not limited to: a. Advertising in any form, including business cards and social media, the unlicensed residence address or landline telephone or facsimile number associated to the unlicensed residence; b. Meeting consumers at, or having consumers come, to an employee’s unlicensed residence; c. Holding out in any manner, directly or indirectly, by the employee or company licensee, the residence address that would suggest or convey to a consumer that the residence is a licensed location for conducting licensable activities; [and] 3. Employees and companiesKider must exercise due diligence in the safeguarding of company and customer data, information and records, whether in paper or electronic format, and to protect them against unauthorized or accidental access, use, modification, duplication, destruction or disclosure.” NMLS State Agency 03/25/20  “The Idaho Department of Finance is closed to the public and Operating Status only limited essential personnel are in the office. Employees spreadsheet are telecommuting and communicating via email. Idaho's responses are in keeping withPC Governor Little's statewide stay-home order and CDC guidelines, and is subject to change 45

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) as the situation requires. Licensees and others are encouraged to use email rather than phone for quicker response as not all employees have phone access.” Update on Agency 03/26/20  “The offices of the Idaho Department of Finance remain open, Operations and but closed to the public for the next 21 days and most of the Communication Due to staff are teleworking from home.” COVID-19 Developments  Communication with the Consumer Finance Bureau should be via email. “All staff will be responding to email throughout the day every business day as they can, and in the order received, during this telework period.” Brodsky “Licensing staff are continuing to process licensing/registration applications through the NMLS and the ‘paper’ system. Delays in ‘paper’ applications and follow-up may occur due to limited access. Companies may choose this time to transition their license records to the NMLS. Requests for supplemental information may be submitted via email. “  “Field examiner staff are conducting streamlined, remote examinations using phone and email correspondence in lieu of traditional on-site examinations.”  The Department has extended the following deadlines” o Mortgage company MCR deadlines – extended 60 days Kider. MCR Q1 2020: extended from May 15, 2020 to July 14, 2020. . MCR Standard Financial Condition: extended from 90 days from end of company’s fiscal year to 150 days from the end of the company’s fiscal year. o Financial Statement deadlines – extended 60 days from 90 days from end of company’s fiscal year to 150 days from end of thePC company’s fiscal year.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS State Agency 03/26/20  Licensees and others are encouraged to use email rather than Operating Status phone for quicker response as not all employees have phone spreadsheet access. NMLS State Agency 04/16/20  “Update for Mortgage Company Operating Status applicants/licensees/registrants: Effective April 10, 2020, due spreadsheet to the COVID-19 issues related to testing and CBC, as well as a change in law that becomes effective July 1, 2020, there will no longer be a requirement for an Idaho mortgage QI to be an Idaho-licensed MLO nor will a VOE be required to demonstrate minimum experience in the industry. Questions Brodsky should be directed to [email protected].” NMLS State Agency 05/18/20  “Update for Mortgage Company Operating Status applicants/licensees/registrants: Effective April 10, 2020, due spreadsheet to the COVID-19 issues related to testing and CBC, as well as a change in law that becomes effective July 1, 2020, there will no longer be a requirement for an Idaho mortgage QI to be an Idaho-licensed MLO nor will a VOE be required to demonstrate minimum experience in the industry. Questions should be directed to [email protected].”  “The Idaho Department of Finance remains generally closed to the public. Most employees are telecommuting and communicating via email, and will be rotating in and out of theKider office through the end of June. Idaho's responses are in keeping with Governor Little's statewide rebound plan, with continued recommendation to telecommunicate where possible, as well as CDC guidelines, and is subject to change as the situation requires. Licensees and others remain encouraged to use email rather than phone for quicker response as not all employees have phone access.” Extension of Temporary 05/22/20 09/01/20  The guidance, addressed to mortgage brokers/lenders and Regulatory Guidance mortgage loans originators,PC among other licensees, extends Regarding Working from the Temporary Regulatory Guidance (see above), issued on 47

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Home Due to March 12, 2020, which temporarily authorized individual Coronavirus/COVID-19 employees of licensees to work at their residence, subject to Concerns or Quarantines certain requirements, even if the residence is an unlicensed location.  The Temporary Regulatory Guidance is extended until September 1, 2020.  “The Department recognizes that as states and municipalities are lifting stay-at-home orders in varying stages, our licensees may need to continue remote operations in certain locations. Additionally, the Department understands that following Brodsky these recent events licensees may want to evaluate whether it is beneficial to their businesses and their consumers to continue utilizing remote operations as part of their business processes.”  “Licensees are still expected to meet the original requirements of the Guidance and should be prepared to meet any existing licensing or registration requirements after September 1, 2020.” Second Extension of 08/12/20 12/31/20  “The Department recognizes that the continued spread of Temporary Regulatory localized person-to-person cases of the virus has not Guidance Regarding significantly improved. As states and municipalities continue Working from Home Due to to lift stay-at-home orders in varying stages, licensees may Coronavirus/COVID-19 stillKider need to continue remote operations in certain locations. Concerns or Quarantines Additionally, the Department understands that licensees may want to continue to evaluate whether it is beneficial to their businesses and their consumers to continue utilizing remote operations as part of their business processes. Therefore, the Department is extending its Temporary Regulatory Guidance until December 31, 2020. Licensees are still expected to meet the requirements of the original Guidance and understand and recognize that the GuidancePC is not an amendment to the

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Idaho Residential Mortgage Practices Act, the Idaho Credit Code or the Idaho Collection Agency Act.” Idaho / Amended Stay-at-Home 04/15/20 04/30/20  The Department of Health and Welfare amended the state- Department of Order of the Director wide stay-at-home order to, among other things, extend the Health and order through April 30, 2020. Welfare Illinois / Office of Executive Order 2020-30 04/23/20  Executive Order 2020-30, among other things, imposes a the Governor moratorium on certain residential eviction actions, “unless a tenant poses a direct threat to the health and safety of other tenants, an immediate and severe risk to property, or a Brodsky violation of any applicable building code, health ordinance, or similar regulation.”  The Executive Order is effective through the of the Gubernatorial Disaster Proclamations. Executive Order 2020-33 04/30/20  Executive Order No. 31 re-issues and extends several (COVID-19 Executive Order executive orders, including, for example: No. 31) o Executive Order 2020-14 (notary and witness guidelines), which is extended through May 29, 2020; and o Executive Order 2020-30 (Filing of residential eviction actions; enforcement of non-residential eviction orders; expired consular identification documents; Kiderelectronic filings for the Illinois Human Rights Commission), which is extended through May 29, 2020. Executive Order 2020-38 05/29/20  Executive Order 2020-38 authorizes the activities paused as a (COVID-19 Executive Order result of the COVID-19 pandemic to resume. No. 36):  The Executive Order includes, for example, requirements and Restoring Illinois - recommendations (e.g., telework) for office buildings. Protecting Our Communities PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order 2020-44 06/26/20  Executive Order 2020-44, in part, re-issues certain prior (COVID-19 Executive Order Executive Orders, including, among others, Executive Order No. 42) 2020-30 (see above). Executive 2020-30 is now re-issued in its entirety and effective through July 26, 2020. Executive Order 2020-48 07/24/20  Executive Order 2020-48, among other things, re-issues, in its (COVID-19 Executive Order entirety, Executive Order 2020-30 (see above), as amended by No. 45) Executive Order 2020-33 (see above). Additionally, Executive Order 2020-48 further amends and revises Executive Order 2020-30 to (1) extend the executive order through August 22, 2020, “whereafter the prohibition on enforcement of orders of Brodsky eviction for non-residential premises shall be rescinded,” and (ii) provide the following new text: o “Section 7. The provisions of Section 2 and 3 of Executive Order 2020-30, as amended by Executive Order 2020-33, prohibiting the commencement of residential eviction actions and the enforcement of orders of eviction for residential properties, shall remain in effect to allow the Illinois Housing Development Authority to distribute monetary assistance under the Emergency Rental Assistance and Emergency Mortgage Assistance programs directly to landlords or property owners on behalf of eligible Kidertenants or, for eligible homeowners, directly to the mortgagor’s loan servicer.” Executive Order 2020-52 08/21/20 09/19/20  Executive Order 2020-52, among other things, is re-issued in (COVID-19 Executive Order its entirety and extended through September 19, 2020, No. 48) Executive Order 2020-30 (Filing of residential eviction actions; enforcement of residential eviction orders; expired consular identification documents; electronic filings for the Illinois Human Rights Commission). Further, Executive Order 2020- 52 revised Section 3 of ExecutivePC Order 2020-30 to the following: 50

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o “Section 3. All state, county, and local law enforcement officers in the State of Illinois are instructed to cease enforcement of orders of eviction for residential premises, unless the tenant has been found to pose a direct threat to the health and safety of other tenants, an immediate and severe risk to property, or a violation of any applicable building code, health ordinance, or similar regulation. Nothing in this Executive Order shall be construed as relieving any individual of the obligation to pay rent, to make Brodsky mortgage payments, or comply with any other obligation that an individual may have pursuant to a , rental agreement, or mortgage.” Executive Order 2020-55 09/18/20 10/17/20  Executive Order 2020-55, among other things, re-issues, in its (COVID-19 Executive Order entirety, Executive Order 2020-30 (see above), as amended by No.51) Executive Order 2020-33 (see above) and Executive Order 2020- 52 (see above), imposing a moratorium on certain residential eviction actions. Executive Order 2020-30 is now extended through October 17, 2020. Illinois / NMLS State Agency 03/23/20 05/01/2020  All Illinois Department of Financial and Professional Department of Operating Status Regulation are working remotely. Financial and spreadsheet Professional Jesse White Allows Notaries 03/27/20  Temporarily,Kider Illinois notaries may perform remote, online Regulation to Perform Duties Remotely notarizations during the COVID-19 pandemic. Due to COVID-19 Pandemic IL Announces Help for 03/30/20  The Illinois Department of Financial and Professional Consumers Struggling to Regulation “announced a series of actions to ensure the Make Payments on their protection of Illinoisans in many areas of consumer Debts Due to the COVID-19 borrowing, servicing, and collections,” in addition to Crisis and Guidance for its providing “Guidance to its regulated entities, state banks, Regulated Financial Sectors credit unions, installmentPC lenders, payday lenders, title loan lenders, sales finance lenders including auto loans, currency 51

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) exchanges, student loan servicers, mortgage servicers, and collection agencies concerning their lending, servicing, and collection during the COVID-19 pandemic.”  With regard to state banks and credit unions, the guidance urges banks and credit unions to assist affected borrowers, specifically encouraging the following actions and reminding these institutions that prudent efforts to offer assistance will not be subject to examiner criticism: o Offering payment accommodations (e.g., payment deferment at no cost, extended payment due dates); Brodsky o New loans on favorable terms; o Fee waivers (e.g., ATM usage fees, overdraft fees, and late fees); o Increasing ATM daily cash withdrawal limits; o Easing restrictions on cashing out-of-state and non- customer checks; o Increasing credit card limits; o Alerting customers to scams and price gouging risks during the COVID19 disruptions; o Sending reminders to customers to contact their financial institutions before entering into unsolicited financial assistance programs; Kidero Preventing service disruptions to consumers and small businesses in the event the financial institutions’ offices close; o Contact customers via app announcements, text, email, or otherwise to explain the above-listed assistance being offered; and o Using capital and liquidity buffers to take other supportive action.  With regard to mortgage servicers,PC the guidance reiterates actions that have already been taken, in addition to 52

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) encouraging consumers to contact their landlord and mortgage servicer for relief programs.  The guidance also addresses student loan servicing, debt collection, and credit history protection. Guidance to Mortgage 03/30/20  The guidance urges mortgage servicers to take action, Servicers & Exempt including the following: Mortgage Servicers Urging o “Forbearing mortgage payments for at least 90 days Support for Borrowers without incurring additional interest or fees; Impacted by COVID-19 o Refraining from reporting late payments to credit rating agencies, and when payments are deferred or Brodsky modified, coding those payments as deferred with the applicable disaster code;” o Offering mortgage borrowers an additional 90-day grace period to complete trial loan modifications, and ensuring that late payments during the COVID-19 pandemic do not affect their ability to obtain permanent loan modifications; o Offering other loss mitigation options to mortgage borrowers, including those that help borrowers stay in their homes at affordable payments; o Waiving late payment fees and online payment fees for a period of at least 90 days and, for mortgage Kiderborrowers in a forbearance plan, during the period of forbearance; o Postponing foreclosures and evictions for at least 90 days; and o Contacting mortgage borrowers on automatic payment plans to see if they need to temporarily suspend those payments and, if so, grant any such requests without delay and place the mortgage borrower in a forbearancePC program as discussed above.” 53

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The guidance also encourages services to take the make the following efforts: o “Ensuring borrowers do not experience a disruption of service if the mortgage servicer reduces staffing or closes an office, including making available other avenues for borrowers to continue to manage their accounts and to make inquiries; and o Contacting borrowers via app announcements, text, email or other effective means to explain the assistance being offered to them.” Brodsky The guidance also reminds institutions that “prudent actions taken during this period will be considered to be consistent with safe and sounding banking practices and will not be subject to examiner criticism” but the Department will “carefully review mortgage servicing activity during this sensitive time for failures to implement federal assistance programs and for any applicable violations of consumer protection law.” Guidance to Student Loan 03/30/20  The guidance encourages Illinois-licensed student loan Servicers Regarding Federal servicers to: Student Loan Interest o “make prudent efforts to meet the financial needs of Waivers and Administrative all student loan borrowers affected directly or Kiderindirectly by the COVID-19 pandemic”; o “navigate their choices regarding their loans in these new and difficult circumstances”; and o “use the disaster status code in conjunction with a deferment when reporting to the consumer credit reporting agencies to minimize any negative credit reporting impact to consumers due to the COVID-19 crisis.”  The guidance also remindsPC Illinois-licensed student loan servicers that they are obligated to avoid any unfair or 54

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) deceptive practices; not misapply the borrowers’ payments; and “lay out” the options available to borrowers (e.g., income- based repayment, deferment, forbearance, relief from interest). Consumer Credit Licensee 03/30/20  “Effective immediately, the Illinois Department of Financial Notice and Professional Regulation (Department) examiners and office personnel will be working remotely. All employees have access to their email and voicemail and will help answer any questions during normal working hours. If you need to speak with an examiner or anyone from the Department’s Brodsky Consumer Credit Section, please leave a voicemail and your phone call will be returned as soon as possible. If an examination was in process, or was scheduled to begin shortly, your examiner will be in contact.” Supplement to Guidance to 04/03/20  The guidance instructs collection agencies whose individual Illinois-Licensed Debt agents are working remotely and whose physical location are Collection Agencies and not changed to email the Department with the employee Debt Buyers Regarding name and location. COVID-19 Pritzker Administration to 04/08/20 04/30/20  “In order to further eliminate barriers that hinder virtual or Allow Remote Notarization remote real estate closings and all related financial During the COVID-19 transactions during the ongoing COVID-19 pandemic, the Pandemic Governor’sKider Office, the Secretary of State’s Office, and the Illinois Department of Financial and Professional Regulation have expanded how real-time electronic technologies may be utilized. Remote notarization can be used for the duration of Governor Pritzker’s stay at home order which is in effect until April 30th.”  The press release also directs readers to the Illinois Secretary of State’s “Guidance for Remote Notaries and Consumers.” Division of Real Estate 04/08/20  Chief Administrative LawPC Judge Donald W. Seasock issued a General Order general order to set all “discovery deadlines on all cases not 55

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) scheduled for formal hearing pending before the Division of Financial and Professional Regulation and Real Estate” for each case’s next scheduled status hearing.  The Order responds to the “unavoidable consequences stemming from COVID-19, including the difficulties in acquiring, accessing or producing discovery materials and disclosures.” Consumer Credit Licensees 04/14/20  The Illinois Division of Financial Institutions published – COVID-19 Best Practices COVID-19 best practices for consumer credit licensees in response to Executive Order 2020-16, suspending through at Brodsky least April 30, 2020, certain statutory provisions related to the /usability of a vehicle and the repossession of vehicles.  The guidance also advises licensees “that the Department will carefully examine lending and collection activity during the COVID-19 crisis.” NMLS COVID-19 Filing 04/16/20  “IL Money Transmitters have 120 days after fiscal year-end to Guidance submit financial statements.” Guide for Consumers 04/27/20  The Department published a guide to financial relief for Struggling to Repay their consumers impacted by COVID-19. Debts During the COVID-19  The guide addresses (i) mortgage payments; (ii) rent Pandemic payments; (iii) student loan payments; (iv) payday, installment,Kider title, and auto loans; (v) communication with collectors; (vi) protecting credit scores; (vii) bank and credit union customers’ options for relief; (viii) stimulus check and wage garnishment protection; and (ix) guidance applicable to the real estate market during the COVID-19 crisis (e.g., social distancing, real estate closings, appraisals, home inspections). NMLS COVID-19 Filing 05/01/20  “Per statute, IL Money Transmitters have 120 days after their Guidance fiscal year-end to submit financial statements. IL has provided an additional 60 days to completePC this requirement, so IL

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Money Transmitters currently have 180 days after their fiscal year-end to submit financial statements.” 'Restore Illinois' Phase 3 05/29/20  The guidance applies to real estate brokerage, appraisers, Recovery Guidance for Real home inspectors, auctioneers, and community association Estate Licensees and managers regarding Illinois’s Phase 3 reopening plan. Consumers  The guidance addresses, among other things, general operation of businesses, office guidelines, meeting guidelines, and profession-specific guidelines. Phase 4: Revitalization for 07/01/20  The guidance assists in implementing Phase 4 of Illinoi’s Real Estate Licensees and (released reopening plan, providing basic guidelines for all real estate Consumers Brodsky07/02/20) professions (e.g., office guidelines), in addition to profession- specific guidelines (e.g., real estate brokerage, appraisers). Indiana / COVID-19 Related 03/20/20  The guidance reiterates that the Indiana Department of Department of Guidance for Financial Institutions (DFI) does not license mortgage branch Financial Indiana DFI-licensed locations, and therefore does not have rules / requirements / Institutions Mortgage Lenders and guidance / restrictions on work location. Mortgage Loan Originators  Regarding licensed MLOs who engage only in brokering (MLOs) activity, the guidance defers to the Indiana Secretary of State Regarding Work from for guidance. Home Informal regulator guidance  DFI continues to process applications and are doing their best to operate as normal as possible. NMLS State Agency 03/23/20  TheKider DFI’s preferred method of communication is email. Operating Status spreadsheet NMLS COVID-19 Filing 04/01/20  The due date for completion of the following reports is Guidance extended by 60 days: o the 2020 Q1 Mortgage Call Report; and o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; and o the 2020 Q1 MSB CallPC Report.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later.  Despite the extended deadlines, the DFI is encouraging licensees to submit reports once ready for submission.  Licensees may request additional time to file the reports in addition to the extensions already provided by submitting the request via email. Requests will be considered on a case-by- case basis. Indiana / Secretary NMLS State Agency 03/17/20  All Indiana Secretary of State personnel are working of State Operating Status remotely. spreadsheet Brodsky For all COVID-19 related questions, please contact Daniel Spungen ([email protected]). NMLS COVID-19 Filing 04/01/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Indiana / Office of Executive Order, 20-22 04/20/20 05/01/20  Executive Order, 20-22, extends the Indiana stay-at-home Governor order through May 1, 2020. Holcomb Iowa / Office of Proclamation of Disaster 03/22/20 04/16/20  The Proclamation of Disaster Emergency, among other things: the Governor Emergency Kidero suspends the “commencement of foreclosure proceedings, or the prosecution of ongoing foreclosure proceedings, on residential, commercial, and agricultural real property located in the state of Iowa,” without relieving individuals of any obligations under a mortgage and for the duration of the Proclamation (or any future extension of this suspension); and o suspends the personal appearance requirement for notarial acts, providedPC that “the notarial act complies with the requirements of section 6 of 2019 Iowa Acts 58

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) chapter 44 (Senate File 475) and any additional guidance provided by the Iowa Secretary of State regarding approved communication technology.” Proclamation of Disaster 05/26/20 06/25/20  Governor Kimberly Reynolds issued a proclamation of Emergency declaration, which, among other things, extends the state of public health disaster emergency through June 25, 2020.  The proclamation of declaration also addresses, among other things, the reopening of businesses and establishments, extensions of closures and orders, mass gatherings, property tax payment relief, electronic meetings and hearings, remote Brodsky notarization and witnessing, and state agency operations. Proclamation of Disaster 06/10/20 06/25/20  The Proclamation of Disaster Emergency, among other things, Emergency (effective extends the proclamation of a state of public health disaster 06/12/20) emergency through June 25, 2020. Proclamation of Disaster 06/25/20 07/25/20  The Proclamation of Disaster Emergency, among other things, Emergency extends the proclamation of a state of public health disaster emergency through July 25, 2020. Proclamation of Disaster 7/24/20 8/23/202  The Proclamation of Disaster Emergency extends the Emergency 7/42 proclamation of a state of public health disaster emergency through August 23, 2020.  The Proclamation also, among other things, continues the temporary suspension of “the regulatory provisions of Iowa CodeKider §§ 144B.3, 633.279, and 633B.105, to the extent that they require the physical presence of a testator, settlor, principal, witness, or other person, if the person is present in a manner in which the witness or other person can see and hear the acts by electronic means, such as video conference, Skype, Facetime, Zoom, or other means, whether or not recorded.” Proclamation of Disaster 09/18/20 10/18/20  The Proclamation of Disaster Emergency extends the Emergency proclamation of a state of public health disaster emergency through October 18, 2020.PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Iowa / Secretary of In-Person Notarization  The guidance is issued pursuant to Governor Reynold’s State Requirement Waiver March 22, 2020 Proclamation of Disaster Emergency, which, Guidance among other things, temporarily waived the in-person requirement for notarizing documents, subject to guidance issued by Iowa Secretary of State Paul Pate.  The guidance provides temporary guidelines for the emergency waive of the in-person requirements until the new remote notary law takes effect on July 1, 2020  Remote Online Notarization FAQs from the Iowa Secretary of State’s office are linked here. ARC 5041C: Rule making Brodsky05/20/20  The Iowa Secretary of State adopted and filed rules amending related to notarial acts (effective Chapter 43, “Notarial Acts,” of the Iowa Administrative Code, 07/01/20) implementing the amendments, effective July 1, 2020, to Chapter 9B, “Notarial Acts,” of the Iowa Code providing for remote online notarization.  Senate File 475, approved by Governor Reynolds on April 29, 2019, providing for the Iowa Code amendments regarding remote online notarization, is linked here. Iowa / Division of Guidance re: Regulatory 03/18/20  Most of the Iowa Division of Banking’s (IDOB) employees are Banking Guidance for Working from working remotely, and the IDOB is encouraging licensees and Residence or Other registrants to do the same. Company Designated  The guidance “expresses the intent of the IDOB to allow Location licenseesKider and registrants, including licensed or registered mortgage loan originators, and their employees to work remotely from their residence or another location designated by the employer during the COVID-19 pandemic, even if the residence or designated location is not a licensed or registered location.” This change is effective immediately and until further notice.  The IDOB also included the following list of best practices for remote workers: PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o “Computers and devices that leave a licensee’s authorized location(s) should include at-rest encryption. o If paper records containing confidential information are taken off the premises of a licensee’s authorized location(s), procedures must be established to secure that information at the offsite location. o Connections to the licensee’s authorized location(s) or sensitive systems via any out-of-office device (e.g., laptop, desktop, phone, tablet) should be encrypted in Brodsky transit by use of a virtual private network (VPN) or similar technology that requires a password or other form of authentication. o Activity should be conducted in a private home environment, avoiding public areas such as coffee shops or libraries.” NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and Kidero the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Updated Interim Guidance 6/23/2020  The guidance, addressed to bank presidents and CEOs, states to Banks that IDOB examinations will continue to be conducted offsite for the “foreseeable future.” Further, for purposes of offsite exams, the IDOB will work with banks that don’t have digital files on a case-by-case basis.  The guidance, among other things, explains the considerations examiners PCwill take into account, including (i) the bank’s success in identifying, documenting, and 61

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) managing risks related to the full scope of the pandemic’s impact on the bank (e.g., “[c]hanges in strategy, technology systems, cyber protections, personnel, operations, and [the bank’s] outlook”), (ii) the bank’s capital levels (and its capital plan if capital shortfalls are possible), and (iii) the bank’s use and implementation of government programs and regulatory relief issuances, (e.g., the SBA’s PPP) specifically with regard to any impact on operations and consumers. Kansas / Office of Executive Order No. 20-10 3/23/20 5/1/20  The original Executive Order, issued on March 17, 2020, Governor Kelly directed and ordered all financial institutions operating in Brodsky Kansas to temporarily suspend the initiation of any mortgage foreclosure efforts or judicial proceedings and any commercial or residential eviction efforts or judicial proceedings.  The updated Executive Order includes the following paragraphs: o “4. No bank or financial lending entity operating in Kansas shall foreclose on a residential property in Kansas when all defaults or violations of the mortgage are substantially caused by a financial hardship resulting from the COVID-19 pandemic. . a. The provisions of paragraph 3 and Kiderparagraph 6 do not apply to foreclosures on multi-family residential properties in which residential tenants rent from a landlord, as long as the foreclosure will not result in the eviction of any tenants.” o “5. No landlords-whether individuals, companies, banks, financial lending entities, nursing homes, long- term care facilities, or other entities-shall evict a residential tenant whenPC all defaults or violations of the rental agreement are substantially caused by a 62

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) financial hardship resulting from the COVID-19 pandemic.” o “6. Any bank, financial lending entity, or landlord initiating judicial foreclosure or judicial eviction proceedings after the effective date of this order shall have the burden of pleading and proving that the foreclosure or eviction proceeding is not being initiated solely because of defaults or violations of mortgages or rental agreements substantially caused by a financial hardship resulting from the COVID-19 Brodsky pandemic.” o “7. This order does not relieve mortgage borrowers or tenants who have not suffered a financial hardship resulting from the COVID-19 pandemic from the obligation to comply with mortgage or rental agreements or to continue making required mortgage or rent payments.” o “8. This order does not prevent foreclosures or evictions for mortgage or rental agreement defaults or violations not due to a financial hardship resulting from the COVID-19 pandemic.” o “9. After the statewide State of Disaster Emergency Kiderproclaimed on March 12, 2020, relating to COVID-19 expires and financial hardships resulting from the COVID-19 pandemic abate, borrowers, lenders, renters, and landlords are encouraged to negotiate payment plans or other agreements to allow borrowers or renters to address any defaults, missed payments, or late fees substantially caused by a financial hardship resulting from the COVID-19 pandemic.” PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order No. 20-24 04/16/20 05/03/20  Executive Order No. 20-24 extends the Kansas stay-at-home order through May 3, 2020. Executive Order No. 20-39 05/26/20 06/30/20  Executive Order No. 20-39 extends, among other things, any professional license (and corresponding renewal deadlines) issued by a state agency to any individual or business (i) in good standing as of March 12, 2020 and (ii) whose license has expired or will expire during the State of Disaster Emergency. Under the extension, the license will remain valid for 90 days following the termination of the State of Emergency.  The Executive Order also extends the deadlines for any Brodsky continuing education requirements required under the extended license. The continuing education requirement deadline is extended for 90 days following the termination of the State of Emergency. Kansas / Office of Remotely Working from 03/16/20  “Licensees (including MLOs), registrants, and their the State Bank Residence or Other employees are allowed to work remotely from their residence Commissioner Company Designated or a company designated location,” provided that prospective Location or existing borrowers do not travel to an MLO’s residence to conduct business. All companies must have temporary policies, procedures, and a plan for supervision in place.  The Kansas Office of the State Bank Commissioner provides the following best practices for remote work: Kidero “Computers and devices that leave the office should include at-rest encryption. o Paper records should not be taken off-site if they contain confidential information. o Connectivity to the main office or sensitive systems should be encrypted in transit by use of a virtual private network (VPN) or similar technology.” KS Executive Order No. 20- 03/17/20 05/01/20  All financial institutions operating in Kansas must 06 – Prohibiting temporarily suspend the initiationPC of any mortgage Foreclosures foreclosure efforts or judicial proceedings and any 64

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) commercial or residential eviction efforts or judicial proceedings until May 1, 2020. NMLS COVID-19 Filing 04/16/20  The due date for completion of the following reports is Guidance extended by 30 days: o 2020 Q1 Mortgage Call Report o MCR Standard Financial Condition o 2019 Q4 MSB Call Report o 2020 Q1 MSB Call Report o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later Remotely Working from Brodsky05/15/20 06/15/20  The guidance authorizing remote work, initially published Residence or Other March 16, 2020 (see above) from locations other than company Company Designated designated locations is extended through June 15, 2020. Location

Remotely Working from 06/15/20 07/15/20  The guidance authorizing remote work, initially published on Residence or Other March 16, 2020 (see above) and previously extended through Company Designated June 15, 2020 (see above), from locations other than company Location designated locations is extended through June 15, 2020.

Remotely Working from 07/07/20 09/15/20  The guidance authorizing remote work, initially published on Residence or Other March 16, 2020 (see above) and previously extended through Company Designated JulyKider 15, 2020 (see above), from locations other than company Location designated locations is extended through September 15, 2020.

Remotely Working from 08/27/20 12/31/20  The guidance authorizing remote work from locations other Residence or Other than company designated locations, initially published on Company Designated March 16, 2020 (see above) and previously extended through Location September 15, 2020 (see above), is extended through December 31, 2020. PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Kentucky / COVID-19 Guidance Sent  The guidance makes the following 5 recommendations for Department of on behalf of Commissioner Kentucky-charted financial institutions: Financial Charles A. Vice o Follow common-sense safety precautions; Institutions o Encourage customers to use mobile apps and online banking; o Work with customers affected by COVID-19 to meet their financial needs (e.g., waiving overdraft and/or minimum balance fees, restructure existing loans, extend loan repayment terms, ease terms for new loans); Brodsky . The Kentucky Department of Financial Institutions has indicated that they will, for regulatory purposes, note actions that financial institutions take to help affected customers. o Manage COVID-19 related staffing issues (note, banks and credit unions making significant alterations to in- person operations should notify the Director of the Division of Depository Institutions); and o Make sure business continuity plans include pandemic planning. NMLS State Agency 03/17/20  All Kentucky Department of Financial Institutions personnel Operating Status are working remotely. spreadsheet Kider NMLS COVID-19 Filing 04/20/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or laterPC due to COVID-19.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) DFI Non-Depository 06/05/20  DFI released guidance making the following Guidance recommendations and mandates for Kentucky non- depositories: o DFI recommends following common-sense safety precautions recommended by health professionals. o All businesses must follow the steps outlined in the Cabinet for Health and Family Service’s Order. The Healthy at Work Minimum Requirements, attached to the Order, are available here and include, for example, conducting daily temperatures and health checks of Brodsky employees. o Businesses subject to the additional requirements outlined in Requirements for Office-Based Businesses must comply with those requirements, available here. o DFI recommends consumer relief measures, including, for example, restructuring existing loans, extending loan repayment terms, easing terms for new loans, and waving fees. . Note, the guidance expresses DFI’s intent, for regulatory purposes, to “note actions taken to help customers affected by issues related to COVID-19. Financial service providers should Kideridentify and monitor accounts and loans, and document any actions taken to assist customers.” o DFI prohibits any Kentucky regulated entity from accepting debit card payments via the telephone if the customer is requested to provide their pin number. o DFI recommends allowing telework when available and “in a manner that is safe to the employee and protects customer PCinformation.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) . Note, the guidance expresses DFI’s intent “not [to] take actions against regulated entities for allowing workers to telework as long as customer information is protected and secure.” Louisiana / Office Emergency Declaration for 03/18/20 04/09/20  Licensees are authorized to temporarily close licensed of Financial Residential Mortgage locations or to “temporarily close and/or relocate some or all Institutions Lenders / Brokers / of the operations, services, and products of a closed location Originators to another location or locations” within Louisiana.  MLOs may “work from home, whether located in State of Louisiana or another state, even if the home is not registered Brodsky with this office.”  “Any licensee whose business is materially affected or interrupted should contact the Office of Financial Institutions as soon as possible with information regarding your temporary relocation.” Commissioner of Financial 04/09/20 04/30/20  John Ducrest, CPA Commissioner Office of Financial Institutions Institutions, issued a modified version of the March 18, 2020 Declared Emergency emergency declaration relative to non-depositories operating Advisory Public Health in Louisiana. Among other changes (e.g., clarifications), the Emergency – COVID-19 For declaration extends the state of emergency, to expire on April Residential 30, 2020 rather than April 9, 2020. Mortgage Lenders/Brokers/Originators Kider 2020 COVID-19 Emergency 05/01/20 05/15/20  The Louisiana Office of Financial Institutions updated its Declarations: Bond for separate 2020 COVID-19 Emergency Declarations for: (i) bond Deed, Check Cashers, for deed, (ii) check cashers, (iii) licensed lenders (LCCL), (iv) Licensed Lenders, pawnbrokers, (v) repossession agencies, and (vi) residential Pawnbrokers, Repossession mortgage lenders (RML). Agencies, Residential  Under the licensed lenders emergency declaration and the Mortgage Lenders residential mortgage lenders emergency declaration, licensees are granted ”the authorityPC to temporarily close licensed locations located within the state or to temporarily close 68

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) and/or relocate some or all of the operations, services, and products of a closed location to another location or locations within the state.” o Licensees materially affected or interrupted by the COVID-19 emergency are instructed to submit temporary changes using the instructions provided in the respective declaration and not use the NMLS (to avoid payments of otherwise required fees). 2020 COVID-19 Emergency 05/15/20 06/05/20  The Louisiana Office of Financial Institutions updated its Declarations: Bond for separate 2020 COVID-19 Emergency Declarations for: (i) bond Deed, Check Cashers, Brodsky for deed, (ii) check cashers, (iii) licensed lenders (LCCL), (iv) Licensed Lenders, pawnbrokers, (v) repossession agencies, and (vi) residential Pawnbrokers, Repossession mortgage lenders (RML). Agencies, Residential  With respect to the licensed lenders emergency declaration Mortgage Lenders and the residential mortgage lenders emergency declaration, the updates extend the previously issued guidance to expire June 5, 2020. 2020 COVID-19 Emergency 06/05/20 06/26/20  The Louisiana Office of Financial Institutions updated its Declarations: Bond for separate 2020 COVID-19 Emergency Declarations for: (i) bond Deed, Check Cashers, for deed, (ii) check cashers, (iii) licensed lenders (LCCL), (iv) Licensed Lenders, pawnbrokers, (v) repossession agencies, and (vi) residential Pawnbrokers, Repossession mortgage lenders (RML). Agencies, Residential  WithKider respect to the licensed lenders emergency declaration Mortgage Lenders and the residential mortgage lenders emergency declaration, the updates extend the previously issued guidance to expire June 26, 2020. 2020 COVID-19 Emergency 06/26/20 07/24/20  The Louisiana Office of Financial Institutions updated its Declarations: Bond for separate 2020 COVID-19 Emergency Declarations for: (i) bond Deed, Check Cashers, for deed, (ii) check cashers, (iii) licensed lenders (LCCL), (iv) Licensed Lenders, pawnbrokers, (v) repossession agencies, and (vi) residential Pawnbrokers, Repossession mortgage lenders (RML) (PCsee above).

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Agencies, Residential  With respect to the licensed lenders emergency declaration Mortgage Lenders and the residential mortgage lenders emergency declaration, the updates extend the previously issued guidance to expire July 24, 2020.  Additionally, the updated residential mortgage lenders emergency declaration is revised to expressly include mortgage servicers within it scope, previously limited to residential mortgage lenders, brokers, and originators. 2020 COVID-19 Emergency 07/24/20  The Louisiana Office of Financial Institutions updated its Declarations: Bond for separate 2020 COVID-19 Emergency Declarations for: (i) bond Deed, Check Cashers, Brodsky for deed, (ii) check cashers, (iii) licensed lenders (LCCL), (iv) Licensed Lenders, pawnbrokers, (v) repossession agencies, and (vi) residential Pawnbrokers, Repossession mortgage lenders (RML) (see above). Agencies, Residential  With respect to the licensed lenders emergency declaration Mortgage Lenders and the residential mortgage lenders emergency declaration, the updates extend the previously issued guidance to remain in effect as long as there is a public health emergency relating to COVID-19, as declared by Governor Edwards, or until rescinded or replaced. Maine / Bureau of Interim Regulatory 03/18/20  The Maine Bureau of Consumer Credit Protection issued Consumer Credit Guidance – Temporarily interim regulatory guidance to licensed MLOs and their Protection Working from Home sponsoring companies.  TheKider interim guidance states that the Bureau will not take punitive action against a licensed MLO or the sponsoring licensee if the MLO works remotely, conducting licensable activity from an unlicensed home, provided that certain data security provisions are met.  Although this interim guidance initially expired on May 1, 2020, this guidance has been extended to July 31, 2020. Agency homepage  “Due to the ongoing COVID-19 health emergency, the offices of the Bureau of ConsumerPC Credit Protection are currently closed to the public. Contact us at (207) 624-8527, and leave a 70

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) message if necessary – staff-members are monitoring all messages and returning all calls.” Foreclosure moratorium, 04/16/20  The Maine Bureau of Consumer Credit Protection and “notices of right to cure Superintendent issued guidance addressed to servicers of default” mortgages secured by Maine residences.  The guidance responds to the CARES Act’s foreclosure moratorium, which applies only to “federally-backed mortgage loans.”  The guidance “strongly urge[s]” all servicers of mortgages secured by Maine residence to adhere to the principles of the Brodsky CARES Act, urging servicers “of all loans . . . to avoid initiating new foreclosures, and to pause any foreclosures in progress.” NMLS COVID-19 Filing 04/23/20  The due date for completion of the following reports is Guidance extended by 30 days: o 2020 Q1 Mortgage Call Report; o MCR Standard Financial Condition; o 2019 Q4 MSB Call Report; o 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Interim Regulatory 07/30/20  The Maine Bureau of Consumer Credit Protection updated its Guidance – Temporarily previouslyKider issued interim regulatory guidance to licensed Working from Home MLOs and their sponsoring companies.  The interim guidance states that the Bureau will not take punitive action against a licensed MLO or the sponsoring licensee if the MLO works remotely, conducting licensable activity from an unlicensed home, provided that certain data security provisions are met.  The update extends this guidance to September 30, 2020. Massachusetts / 2020 MA HB 4647 04/20/20 08/18/20  Massachusetts House Bill PC4647 (Chapter 65 of the Acts of State Legislature 2020), effective immediately, imposes a temporary 71

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) moratorium on certain evictions and foreclosures for residential dwelling units or small business premises during the COVID-19.  The Act expires on the earlier of August 18, 2020 or 45 days after the COVID-19 emergency declaration is lifted. MA S 2645: Chapter 71 of 04/27/20  The Act temporarily authorizes a notary public to “perform the Acts of 2020 an acknowledgement, affirmation or other notarial act . . . utilizing electronic video conferencing in real time,” subject to certain requirements.  “[W]ith respect to any document requiring notarization and Brodsky executed in the course of a transaction involving a mortgage or other conveyance of title to real estate . . . only a notary public appointed pursuant to chapter 222 of the General who is an attorney licensed to practice law in the commonwealth or a paralegal under the direct supervision of such an attorney, shall perform an acknowledgment, affirmation or other notarial act utilizing electronic video conferencing in real time as provided in this act.”  The temporary authorization or remote notarization will be repealed 3 business days after termination of the governor’s declaration of the state of emergency. Massachusetts / Reminder to Licensees 03/11/20  LicenseesKider are allowed “to work from home, provided the Division of Banks arrangement is feasible for their business model and license type, that it is not advertised as an office, and that the licensee does not meet consumers at their home.” Reminder to Mortgage 03/12/20  The reminder is to lenders to encourage them to engage their Lenders & Funding Sources funding partners to ensure lines of credit remain accessible and adequate to meet current and anticipated funding needs. NMLS State Agency 03/16/20  All Massachusetts Division of Banks (DOB) personnel are Operating Status working remotely. PC spreadsheet 72

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  “Email is the preferred method of communication. Telephone calls/messages will be responded to as normal.” Notification Protocol 03/19/20  The guidance allows licensees to temporarily close a facility due to staffing challenges or as a precautionary measure. Licensees should notify: (1) customers of temporary closures and the availability of alternative service options (if any); and (2) the DOB of any location closures, business disruptions, or other significant developments related to COVID-19 (e.g., office closures, significant staff shortages, liquidity shortages, distress with funding sources, issues funding closed loans). Response to Governor’s Brodsky03/23/20  In response to the Governor’s emergency order requiring Emergency Order closure of all businesses and organizations not providing “COVID-19 Essential Services,” the DOB considers all entities charted and licensed by the Division covered by the essential services list and, therefore, exempt from the Governor’s order. Reporting Deadline 03/26/20  The Division has agreed to follow the policy as proposed by Changes for Massachusetts the NMLS Policy Committee to provide a 60 day extension to Licensees and Registrants all Licensees to submit Call Reports and financial statements.  Additionally the Division is temporarily instituting a policy to extend the Annual Report deadline by 60 days for regulated entities that cannot meet the original deadlines due to COVID-19. Kidero Debt Collector 2019: extended from March 31, 2020 to May 30, 2020 o Check Casher 2019: extended from March 31, 2020 to May 30, 2020 o Finance Company 2019: extended from March 31, 2020 to May 30, 2020 o Foreign Transmittal Agency 2019: extended from March 31, 2020 to May 30, 2020 o Loan Servicer 2019:PC extended from March 31, 2020 to May 30, 2020 73

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  “On March 18, 2020, Prometric testing sites were closed for a period of at least 30 days to mitigate the spread of Coronavirus/COVID-19.” Message to Massachusetts 03/30/20  The Division extending the following deadlines: Licensees and Registrants o Financial statement deadline – from 90 days from end on Deadlines of the company’s fiscal year to 150 days from the end of the company’s fiscal year. . Note, the Division is maintaining this 60-day extension, despite the current NMLS policy decision implementing the financial statement Brodsky deadline’s 30-day extension. o Call report deadlines: . MSB Q4 – from March 21, 2020 to April 30, 2020 . MCR Q1 – from May 15, 2020 to June 14, 2020 . MSB Q1 – from May 15, 2020 to June 14, 2020 . MCR Standard Financial Condition – from 90 days from the end of the company’s fiscal year to 120 days from the end of the company’s fiscal year. . Note, the Division is following the new NMLS policy to provide a 30-day extension for all Kiderlicensees. o Annual report deadlines. The following reports are extended from March 31, 2020 to May 30, 3030: Debt Collector 2019 report, Check Casher 2019 report, Finance Company 2019 report, Foreign Transmittal Agency 2019 report, Loan Servicer 2019 report. The 60- day extension is available for regulated entities that cannot meet the original March 31, 2020 deadline as a result of the COVIDPC-19 emergency.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; and o the 2020 Q1 MSB Call Report.  The due date for completion of the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later is extended by 60 days. DOB Industry Guidance Re: 04/06/20  The supervisory guidance responds to the U.S. Small Business SBA’s Paycheck Protection Brodsky Administration’s new Paycheck Protection Program (PPP), Program and Legal Lending authorized under the Coronavirus Aid, Relief, and Economic Limits Security Act.  The Massachusetts DOB concluded that “loans made specifically under the PPP will not be considered as the basis for an adverse regulatory finding or enforcement action for violation of the legal lending limit. Similarly, to the extent that such a PPP loan would cause the institution to exceed the lending limit established by its own internal policy, which may be an amount less than the legal lending limit established by the Massachusetts law, such exception to exceed the maximum borrowing amount would not be criticized in the findingsKider of an examination as a variation from the institution’s lending policy.”  Additionally, the DOB emphasized that “this supervisory exception to the legal lending limit is being granted specifically for, and only to the extent of, the PPP loan amount.” FAQ: Chapter 65 of the Acts 04/24/20  The FAQs respond to questions relating to the of 2020, An Act Providing implementation of 2020 MA HB 4647. for a Moratorium on PC Evictions and Foreclosures 75

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) During the COVID-19  The FAQs address the foreclosure moratorium and Emergency forbearance period, reverse mortgages, and other implementation considerations.  With respect to the foreclosure moratorium and forbearance period, the FAQs address, among other things: (i) the length of the Act’s temporary moratorium on evictions and foreclosures; (ii) borrower eligibility to obtain forbearance on mortgage payments; (iii) procedures for obtaining a forbearance; (iv) the impact of the 180-day forbearance; (v) the availability of alternatives to entering into a forbearance Brodsky period; and (vi) the impact of forbearance on obligations that may become due during the forbearance period (e.g., property tax and insurance premiums). Industry Guidance Relative 04/27/20  The guidance addresses the impact of the recently enacted to Compliance with Reverse Chapter 65 of the Acts of 2020 (2020 MA HB 4647) on the in- Mortgage Counseling person counseling requirement for reverse mortgages. Requirements under  The guidance addresses the Act’s Section 2, which “provides Chapter 65 of the Acts of that from the effective date of the Act until the termination of 2020 the Governor’s declaration of the State of Emergency, the in- person counseling requirement under M.G.L. c. 167E, s. 7A and M.G.L. c. 171, s. 65C½ can be met by synchronous, real- time video conference or telephone in lieu of the in-person requirement.”Kider o “ In short, the Act provides that counseling for reverse mortgages may be conducted via one of the following options: (1) in person, (2) by synchronous, real-time video conference, or (3) by telephone. This change is in effect only from April 20, 2020 until Governor Baker declares an end to the current State of Emergency. Once the State of Emergency has concluded, in person counseling shall oncePC again be required.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The following guidance is provided to implement the Act’s Section 2: o The Division adopts the position that the in-person counseling requirements “are met if the counseling takes place via synchronous, real-time video or by telephone, while the State of Emergency is in effect.” o The Division notes that the HUD Certificate of HECM Counseling only provides face-to-face counseling or telephone counseling options. The Division concludes that “[i]f the counseling takes place via synchronous, Brodsky real-time video, then the counselor would check the box on the Certificate for telephonic counseling.” o “With regard to non-HECM programs (so-called “proprietary” programs) for reverse mortgages, it is also the position of the Division that the counseling options permitted under the Act apply to all types of approved reverse mortgage programs in Massachusetts, including HUD HECM and any approved proprietary reverse mortgage program.” FAQ: Chapter 65 of the Acts Rev. 05/01/20  The Massachusetts Division of Banks updated its FAQs of 2020, An Act Providing responding to questions relating to the implementation of for a Moratorium on 2020 MA HB 4647 (see MA state legislature updates). Evictions and Foreclosures  TheKider updated FAQs clarify that the relief afforded under During the COVID-19 Chapter 65, like the federal CARES Act, is intended only for Emergency – UPDATED borrowers experiencing a financial hardship caused by COVID-19—i.e., borrowers not adversely impacted must continue to meet their mortgage obligations.  The updated FAQs also add additional questions and answers relating to the foreclosure moratorium and forbearance period, addressing, for example: (i) the inability of a lender or servicer to impose chargesPC beyond what is due under an existing mortgage agreement; (ii) memorializing forbearance 77

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) agreements; (iii) the scope of Chapter 65’s forbearance provisions (e.g., applicability to property other than a primary residence); (iv) eligibility for a forbearance despite an existing delinquent status; and (v) written affirmation requirements related to financial impact caused by COVID-19. Guidance Relative to 05/01/20  The Massachusetts Division of Banks issued letters to Insurance Premium Finance insurance premium finance companies to highlight the Companies Massachusetts Division of Insurance Bulletin 2020-05, released on March 23, 2020.  “Given the Division of Insurance’s expectation that insurance Brodsky carriers explore relief options for policyholders prior to cancellation, the Division of Banks similarly expects Insurance Premium Finance Companies will work to provide flexibility and relief to customers during the COVID-19 state of emergency.”  The Division of Insurance’s bulletin is linked here. Industry Guidance 06/12/20  The Division of Banking published guidance to clarify the Regarding Annual Meetings “supervisory expectations,” during the COVID-19 emergency, for Massachusetts State- concerning the required annual meeting applicable to Chartered Mutual Banks “mutual institutions,” for purposes of the 2020 annual and Subsidiary Banks of a meeting only. Massachusetts Mutual o Note, “mutual institutions” is defined to include: (i) Holding Company Kiderdepositors of mutual banks (i.e., mutual co-operative banks and corporators of mutual savings banks) and (ii) mutual holding companies and their Massachusetts state-chartered subsidiary banks.  The guidance provides mutual institutions the option to either (i) postpone the in-person annual meeting or (ii) conduct the annual meeting by remote communication. o Mutual institutions opting to postpone the in-person annual meeting should,PC within 60 days of the end of the state of emergency, (i) conduct the in-person 78

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) meeting or (ii) issue a notice identifying the date of the in-person meeting if scheduled after the 60-day period. o Mutual institutions opting to conduct the annual meeting remotely are subject to certain requirements, including, allowing participation via telephone, including provisions to allow the institution to verify the identity of participant, and ensuring the remote meeting does not violate any provisions of the institution’s bylaws. The guidance also includes Brodsky certain recommendations, including, making technical support available, extended meeting duration and voting by mail, and the election of a remote meeting in board minutes. Industry Guidance 06/12/20  The Division of Banking published guidance to clarify the Regarding Annual Meetings “supervisory expectations,” during the COVID-19 emergency, for Massachusetts Chartered concerning the required annual meeting applicable to Credit Unions Massachusetts-charted credit unions, for purposes of the 2020 annual meeting only.  The guidance responds to Executive Order No. 591, published on March 10, 2020, prohibiting the gatherings of 10 or more individuals, directly impacting credit unions.  TheKider guidance provides credit unions the option to either (i) postpone the in-person annual meeting or (ii) conduct the annual meeting by virtual or hybrid (i.e., virtual meetings with limited in-person attendance) means with voting by mail. o With respect to credit unions opting to postpone the in-person annual meeting, the guidance specifies: “A Massachusetts credit union that has not yet held its 2020 annual memberPCship meeting may postpone its annual meeting until the State of Emergency is lifted, 79

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) the Order has expired or is rescinded, or such time as the credit union believes it may safely hold its annual meeting. The Division recognizes that even after the State of Emergency is lifted and the Order expires or is otherwise no longer in effect, that adhering to recommended social distancing protocols or guidance may nonetheless counsel against holding an in-person annual meeting of the membership.” Further, the guidance recognizes the possible inability to hold an in-person meeting during the year 2020. Brodsky o Credit unions opting to conduct the annual meeting remotely are subject to certain requirements, including, for example, notification of the virtual/hybrid meeting in accordance with bylaws, including a meeting agenda in such notification, and verification of the participants identity. . The guidance also includes certain recommendations, including, making technical support available and extended meeting duration and voting by mail. FAQ: Chapter 65 of the Acts Rev. 08/27/20  The Massachusetts Division of Banks updated its FAQs of 2020, An Act Providing responding to questions relating to the implementation of for a Moratorium on 2020 MA HB 4647 (see MA state legislature updates). Evictions and Foreclosures  TheKider updated FAQs reflect the extended foreclosure During the COVID-19 moratorium, previously set to expire on August 18, 2020 and Emergency – UPDATED now set to expire on the earlier of October 17, 2020 or 45 days after the COVID-19 emergency declaration. Massachusetts / 400 CMR 5.0: COVID-19 04/24/20 08/18/20  Massachusetts Executive Office of Housing and Economic Executive Office of Emergency Regulations Development (EOHED) promulgated emergency regulations, Housing and required by 2020 MA HB 4647. Economic o The Act directs EOHED to implement Section 3 of the Development Act, addressing nonPC-essential evictions, and Section 4

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) of the Act, addressing landlord’s rights and responsibilities. o “The Act also requires EOHED to (1) develop forms and recommendations for the provision of notice and documentation to a landlord that a non-payment of rent was due to a financial impact from COVID-19, and (2) promulgate a standard form for the notification of tenants under subsection (a) of section 4 of the Act.”  The emergency regulation expires on the earlier of August 18, Brodsky 2020 or 45 days after the COVID-19 emergency declaration is lifted. Massachusetts / Baker-Polito Administration 04/28/20  “[T]he Baker-Polito Administration extended the essential Office of the Extends Non-Essential services emergency order to May 18th and launched a Governor Business Closures to May Reopening Advisory Board that will produce a plan to the 18th, Announces Reopening Governor by May 18th. The Administration also announced Advisory Board that the Department of Public Health’s Stay At Home Advisory remains in effect and gatherings of 10 or more people remain prohibited until May 18th.” Reopening Massachusetts  The Office of Governor Charlie Baker and the Executive Office of Housing and Economic Development published a comprehensive four-phase plan to reopen Massachusetts.  TheKider guidance includes, among other things, general business guidance regarding the self-certification requirement to reopen (e.g., a COVID-19 control plan template—linked here—that will satisfy the written control plan requirement for self-certification).  The guidance also includes guidance tailored to office spaces, permitted to reopen on May 25, 2020 (with the exception of Boston offices, which are permitted to reopen on June 1, 2020). The guidance includes, amongPC other things, a checklist for

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) actions to be taken to reopen. The list office-specific guidance is linked here, and the office-specific checklist is linked here. COVID-19 Order No. 35 06/01/20  COVID-19 Order No. 35 implements Phase II of Massachusetts’s reopening plan. Foreclosures and Evictions 07/21/20 10/17/20  Governor Baker extended the moratorium on evictions and Moratorium Extension July foreclosures until October 17, 2020, pursuant to the authority 21 2020 granted to Governor Baker by Chapter 65 of the Acts of 2020 (see above). Maryland / Office Renewal of Declaration of 07/01/20  The Declaration, among other things, renews the March 5, of the Governor State of Emergency 2020 proclamation of a State of Emergency and Existence of Brodsky Catastrophic Healthy Emergency. Renewal of Declaration of 7/30/20  The Renewal Declaration of State of Emergency renews the State of Emergency March 5, 2020 proclamation of a State of Emergency and Existence of Catastrophic Healthy Emergency. Order of the Governor of the 09/29/20  Executive Order No. 20-09-29-01 amends and restates, in its State of Maryland Number entirety, Emergency Order 20-03-30-04 of the Governor of the 20-09-29-01 Amending the State of Maryland, dated March 30, 2020, entitled, Order of March 30, 2020, “Authorizing Remote Notarizations.” Authorizing Remote  Specifically, the Executive Order adds the following: Notarizations o “Subject to all other applicable law, regulations, and guidance issued by the Secretary of State, notaries public located in Maryland may perform a notarial act Kiderusing communication technology for a remotely located individual with respect to: (a) a will, as defined in § 1-101 of the Estates and Trusts Article of the Maryland Code (“ET”); and (b) a trust instrument, as defined in ET § 14.5-103.” Renewal of Declaration of 10/06/20  The Renewal Declaration of State of Emergency, among other State of Emergency and things, renews the March 5, 2020 proclamation of a State of Existence of Catastrophic Emergency and Existence of Catastrophic Healthy Health Emergency – Emergency. PC COVID-19 82

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Renewal of Declaration of 10/29/20  The Declaration, among other things, renews the March 5, State of Emergency and 2020 proclamation of a State of Emergency and Existence of Existence of Catastrophic Catastrophic Healthy Emergency, without specifying an end Health Emergency – date. COVID-19 Maryland / Court Second Amended 08/11/20  The Court of Appeals of Maryland’s Second Amended of Appeals Administrative Order Administrative Order, among other things: Lifting the Suspension o rescinds the following June 3, 2020 administrative During the COVID-19 order: Amended Administrative Order on Lifting of the Emergency of Foreclosures, Suspension During the COVID-19 Emergency of Evictions, and Other Brodsky Foreclosures, Evictions, and Other Ejectments Ejectments Involving Involving Residences, available here; Residences o specifies requirements for evictions and other ejectments, including a required certification for filing certain complaints for failure to pay rent; and o requiring the filing of specific declarations, concerning exemption from the moratorium, for certain foreclosure actions. Maryland / COVID-19 Bulletin for MD 03/13/20  Pursuant to the Code of Maryland Regulations, MLOs may Department of Mortgage Brokers, Lenders work from home, or another unlicensed location, if it is Labor / Office of and Servicers necessary for the office to close due to an emergency, the Commissioner providedKider that neither the MLO nor the MLO’s employer of Financial engages in any of the following: (1) Owns or the Regulation location for the purpose of conducting mortgage lending business; (2) Indicates or suggests by use of signage that the mortgage loan originator or the mortgage loan originator’s employer utilizes the location for taking mortgage loan applications or offering or negotiating terms of mortgage loans; (3) Advertises that the mortgage loan originator or the mortgage loan originator’sPC employer takes mortgage loan applications or offers or negotiates terms of mortgage loans at 83

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) the location; (4) Maintains work space, telephone service, or internet service at the location in the name of the mortgage loan originator or the mortgage loan originator’s employer for the purpose of conducting mortgage lending business; (5) Receives mail relating to the mortgage lending business at the location; or (6) Stores books or records relating to the mortgage lending business at the location.”  The Maryland Office of the Commissioner of Financial Regulation (OCFR) intends to continue the required periodic exams of all mortgage lender licensees but has stated they are Brodsky willing to be flexible on timelines involving examinations or other licensing or supervisory activity required under Maryland law.  The OCFR has stated that their preferred method of communication is email (either to Christine Brooks for examination concerns or Arlene Williams for licensing concerns). Foreclosure of Residential 03/19/20  The Maryland Court of Appeals issued an administrative Property Stayed order immediately staying all foreclosures of residential properties in Maryland. Guidance to Mortgage 03/24/20  The Commissioner “strongly urges” licensed mortgage Servicers servicers to immediately mitigate the COVID-19’s impact on customers,Kider by, “at a minimum,” taking reasonable steps to attempt to offer assistance to all Maryland borrowers who have experienced impacts affecting their ability to pay mortgages (e.g., loss of income). o “Reasonable steps” to immediately take include: “1. Waiving late fees as well as online and telephone payment fee; 2. Forgoing the reporting of payment information during the health emergency or reporting payment informationPC to credit reporting agencies in a manner that minimizes the impact of delinquent 84

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) payment on a borrowers’ credit histories; 3. Offering forbearance or other options, when permitted under investor guidelines, to allow borrowers to defer payments (such deferral programs should take into account the ability of the borrower to meet payment obligations when the forbearance period ends with a goal towards preserving homeownership – such as extending the loan term to accommodate the missed payments); 4. Extending trial modification periods and ensuring that late payments resulting from Brodsky COVID-19-related interruptions to income do not prevent borrowers from obtaining permanent modifications; 5. Taking steps to ensure that borrowers are able to timely make inquires and manage their accounts, and, if there is a reduction in the servicer’s staff, ensuring that borrowers are provided with alternatives for managing accounts, making inquiries, and making payments; 6. Reaching out to borrowers proactively to provide information on available assistance; 7. Ensuring that all borrower- facing staff are fully informed regarding any assistance available and are proactive in informing Kiderborrowers of such.“ Executive Order Authorizes 03/31/20  The advisory reports Governor Hogan’s March 30, 2020 Remote Notarization: executive order permitting remote notarization, “if the notary Mortgage Lenders and the party whose signature is being notarized Encouraged to Implement communicate with each other simultaneously by sight and Remote Closings sound through a communication technology, and the notary is able to view satisfactory of the party’s identity.”  The advisory urges mortgage lenders to use remote notarization to close loans.PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Industry Advisory: 04/06/20  Pursuant to Governor Hogan’s April 3, 2020 Executive Order Executive Order Regarding (effective 20-04-03-01 and beginning on April 10, 2020, the Maryland Notices of Intent to 04/10/20) Commissioner is suspending operation of the Notice of Intent Foreclose to Foreclose Electronic System and discontinuing acceptance of Notices of Intent to Foreclose until the state of emergency is over.  Until April 10, the system will continue to operate “solely to accommodate submissions of notices of intent to foreclose which were sent to consumers prior to the Governor’s issuance of the Order.” Industry Advisory: Brodsky04/06/20  The Industry Advisory responds to Governor Hogan’s April Executive Order Regarding 3, 2020 Executive Order 20-04-03-01. “Licensees must Repossessions immediately cease any and all self-help repossessions of automobiles, trucks, and chattel homes ( used as a person’s residence, including without limitation, mobile homes, trailers, and live-aboard boats).” Advisory: Legal Lending 04/17/20  The Maryland Commissioner of Financial Regulation issued Limit COVID-19 Pandemic guidance to banks and credit unions to address the current or Guidance anticipated lending limit issues arising from COVID-19 financial control measures. The guidance allows for certain exemptions to state and federal lending limits, as applicable. Industry Advisory: CARES 04/30/20  The Industry Advisory responds to the relief payments issued Act Relief Payments: toKider consumers under the CARES Act, as well as the Maryland COVID-19 Pandemic Executive Order 20-04-29-03, issued on April 29, 2020, which GUIDANCE: Guidance for prohibits garnishment of CARES Act recovery rebates. Non-Depository Financial  The Industry Advisory requires all licensees to “cease any and Services Providers all garnishment and/or set-off activity on said Relief Payments, whether directly or through an authorized agent.”  “To the extent a licensed business entity inadvertently receives the proceeds of the Relief Payments, they should endeavor to rectify this mistakePC in order to permit those funds to be used by Maryland taxpayers for the intended purposes. 86

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Should it be determined that a licensed entity willfully or negligently violates the dictates of the Governor’s Order, such entity may be subject to regulatory action to the fullest extent of the law.” Industry Advisory 07/13/20  The guidance responds to a new regulation issued by the Regulatory Notice: Sale of Commissioner of Financial Regulation July 16, 2020, codified Loan Accounts by as Code of Maryland Regulations (COMAR) 09.03.10.04. The Consumer Loan Licensees: regulation “clarifies the meaning of the term, “loan account,” Clarification as used in FI §12-219 by stating that the term refers to only those loans governed by the Maryland Consumer Loan Law, Brodsky and that it does not refer to installment loans as defined in FI §11-302(a). Thus, a holder of a consumer loan license may sell an installment loan to a person who does not hold a consumer loan license, and an installment loan purchased by a person who does not hold a consumer loan license remains enforceable.”  The guidance clarifies and emphasizes that “[t]he new regulation does not alter the statutory prohibition on the sale of a loan subject to the Maryland Consumer Loan Law to an unlicensed person, nor the provision that renders the loan unenforceable if sold to an unlicensed person.” Information on 07/15/20  The guidance advises Maryland-chartered depository Identification Requirements institutionsKider Maryland-chartered depository institutions and for Customers of Non- Maryland-chartered depository institutions, in separate Depository Financial industry advisories, that they can continue to accept, as valid Services Providers: identification, driver’s licenses and/or identification cards that Maryland Extended expired or are eligible for renewal after March 12, 2020.” Deadline for License  The guidance responds to Executive Order 20-06-19-01, which Renewals extended “extending the expiration date for certain licenses, Information on permits and registrations that expire or are eligible for Identification Requirements renewal during the state ofPC emergency to ‘the 30th day after for Customers of Depository 87

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Institutions: Maryland the date by which the state of emergency is terminated and Extended Deadline for the catastrophic health emergency is rescinded.’” License Renewals Industry Advisory: FAQs 11/09/20  The Industry Advisory provides FAQs responding to Regarding Foreclosure and Governor Hogan’s Executive Order Number 2020-10-16-01 Repossession (see above).  The FAQs primarily address notices of intent to foreclose and forbearances and other obligations.  With respect to Notices of Intent to Foreclose (NOIs), the FAQs clarify that the Maryland Commissioner of Financial Brodsky Regulation will resume accepting NOIs through the NOI Electronic System on January 4, 2021; until then, an NOI may not be sent to a borrower (either through the NOI Electronic System or outside of the system) while the NOI Electronic System is closed.  With respect to forbearances and other obligations, the FAQs clarify, among other things, the following: o The Executive Order applies only “prospectively to any Mortgage Loan in which a copy of the NOI is submitted to the Commissioner after the NOI Electronic System reopens on January 4, 2021.” The Order does not apply “to a Mortgage Loan for which Kideran NOI was sent to the Borrower and a copy is submitted to the Commissioner through the NOI Electronic System prior to April 3, 2020”; o “A Servicer is not required to provide any of the relief provided for under Section IV of the Order. If a service fails to offer such relief, however, and it had not already sent an NOI to the borrower and submitted that NOI to the Commissioner through the NOI Electronic System PCprior to April 3, 2020, it will be unable to pursue an effective foreclosure until the 88

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) earlier of the time that it does comply with Section IV or the Order’s mandate has terminated; o Non-Federal Mortgage Loans and Federal Mortgage Loans are to be treated equally; o Other servicer-specific procedures related to forbearances. Michigan / Office Executive Order 2020-21 03/24/20 4/13/20  The Executive Order imposes a temporary requirement to of the Governor suspend activities that are not necessary to sustain or protect life. Executive Order 2020-41 04/08/20 05/06/20  Executive Order No. 2020-41 temporarily suspends strict Brodsky compliance with the Uniform Electronic Transactions Act and the Uniform Real Property Electronic Recording Act “to the extent necessary to permit the use of an electronic signature for a transaction whenever a signature is required under Michigan law, unless the law specifically mandates a physical signature.”  The Executive Order also temporarily suspends strict compliance with the Michigan Law on Notarial Acts “to the extent it requires a notary to be in the physical presence of an individual seeking the notary’s services or of any required witnesses.” o The Executive Order allows any required notarial act Kiderto be performed by a notary with a valid notarial commission in Michigan using two-way real-time audiovisual technology, provided that certain conditions are met.  The Executive Order allows the use of two-way real time audiovisual technology to satisfy any requirement under Michigan law that an in-person witness attest to or acknowledge an instrument, document, or deed, provided that certain conditions arePC met.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order 2020-42 04/09/20 04/30/20  The Executive Order 2020-42 rescinds and replaces Executive Order 2020-21.  The Executive Order 2020-42 reaffirms the Executive Order 2020-21 measures, clarifies them, and extends their duration through April 30, 2020.  FAQs providing guidance on Executive Order 2020-42 are linked here. Executive Order 2020-59 04/24/20 05/15/20  Executive Order No. 2020-59 rescinds Executive Order No. 2020-42 and imposes a temporary requirement to suspend activities that are not necessary to sustain or protect life, but Brodsky allows for certain workers to return to work, subjected to limitations.  FAQs relating to the implementation of Executive Order No. 2020-59 are linked here. Executive Order No. 2020- 04/30/20  Executive Order No. 2020-66 terminates the state of 66: Termination of the states emergency and state of disaster declared under the of emergency and disaster Emergency Management Act in Executive Order 2020-33. declared under  The Executive Order reflects the Emergency Management the Emergency Management Act’s provision that “that a declared state of emergency or Act in Executive Order disaster shall continue until the governor finds that the threat 2020-33 or danger has passed, the [disaster/emergency] has been dealt with to the extent that [disaster/ emergency] conditions no longerKider exist, or until the declared state of [disaster/ emergency] has been in effect for 28 days. After 28 days, the governor shall issue an executive order or proclamation declaring the state of [disaster/ emergency] terminated, unless a request by the governor for an extension of the state of [disaster/emergency] for a specific number of days is approved by resolution of both houses of the legislature.”  The Executive Order reports that the state legislature has “refused to extend” the declaredPC state of emergency.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order No. 2020- 04/30/20 05/28/20  Executive Order No. 2020-67 declares a state of emergency 67: Declaration of state of under the Emergency Powers of the Governor Act. emergency under the Emergency Powers of the Governor Act Executive Order No, 2020- 05/01/20 05/15/20  Executive Order 2020-70 reaffirms Executive Order 2020-59 70: Temporary requirement (see above) and, among other things, expands the scope of to suspend activities that activities permitted to resume. are not necessary to sustain  Among others, workers permitted to resume include: or protect life; o Effective May 7, 2020, “workers in the real-estate Rescission of Executive Brodsky industry, including agents, appraisers, brokers, Order 2020-59 inspectors, surveyors, and registers of , provided that: (1) Any showings, inspections, appraisals, photography or videography, or final walk-throughs must be performed by appointment and must be limited to no more than four people on the premises at any one time. No in-person open houses are permitted [and] (2) Private showings may only be arranged for owner-occupied homes, vacant homes, vacant land, , and industrial property.” o Effective May 7, 2020, “workers in the construction industry, including workers in the building trades Kider(plumbers, electricians, HVAC technicians, and similar workers),” subject to social-distancing rules specific to the construction industry, as described in the Order. Executive Order No. 2020- 05/05/20 06/30/20  Executive Order No. 2020-74 rescinds Executive Order No. 74: 2020-41 (see above) and re-issues the relief provided, regarding Encouraging the use of authorizing remote notarization, with the following changes: electronic signatures and o Executive Order No. 2020-74 extends the relief remote notarization, through June 30, 2020. o Executive Order No.PC 2020-74 expands the relief in the following two ways: 91

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) witnessing, and visitation . Certain conditions necessary for using two- during the COVID-19 way real-time audiovisual technology to satisy pandemic; any requirement under Michigan law that an Rescission of Executive in-person witness attest to or acknowledge an Order 2020-41 instrument are relaxed (i.e., the time period to transmit a copy of the document is expanded from 24 hours to 72 hours). . “Strict compliance with section 9(2) of the Michigan Law on Notarial Acts, as amended, MCL 55.269(2), is temporarily suspended to the Brodsky extent necessary to extend until June 30, 2020 the validity of a notarial commission that expired or is set to expire between March 1, 2020 and June 30, 2020.” Executive Order No. 2020- 05/14/20 06/11/20  Executive Order No. 2020-85, among other things, orders that, 85: Temporary prohibition effective immediately and through June 11, 2020: against entry to premises for o “no person may remove or exclude from leased the purpose of removing or residential premises or residential premises held excluding a tenant or mobile under a forfeited executory contract a tenant, a vendee home owner from their of a forfeited executory contract, or a person holding home; Rescission of under a tenant or vendee, except when the tenant, Executive Order 2020-54 vendee, or person holding under them poses a Kidersubstantial risk to another person or an imminent and severe risk to property”; and o “no person may enter residential property in order to remove or exclude from the premises a tenant, a vendee of a forfeited executory contract, a person holding under a tenant or vendee, or the personal property of a tenant, vendee, or person holding under them, including pursuant to a writ authorizing restoration of a plaintiffPC to full, peaceful possession of premises under section 5744 of the RJA, MCL 600.5744, 92

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) except when the tenant, vendee, or person holding under them poses a substantial risk to another person or an imminent and severe risk to property.” Executive Order 2020-92: 05/18/20 05/28/20  Executive Order No. 2020-92, among other things, extends the Temporary requirement to stay-at-home order through May 28, 2020. suspend certain activities that are not necessary to sustain or protect life; Rescission of Executive Orders 2020-77 and 2020-90 Brodsky Executive Order No. 2020-96 05/21/20 05/28/20  Executive Order No. 2020-96 reaffirms Executive Order No. Temporary requirement to 2020-92 with certain changes, including, for example, suspend certain activities allowing gatherings up to 10 people statewide. that are not necessary to sustain or protect life Rescission of Executive Orders 2020-17, 2020-34, and 2020-92 Executive Order No. 2020-99 05/22/20 06/19/20  Executive Order No. 2020-99 extends the state of emergency Declaration of state of declaration responding to the COVID-19 pandemic. emergency and state of disaster related to the Kider COVID-19 pandemic Executive Order No. 2020- 05/22/20  Executive Order No. 2020-100, among other things, extends 100: Amending certain Executive Order No. 96 (see above) through June 12, 2020. previously issued executive orders to clarify their duration Executive Order No. 2020- 06/01/20  Executive Order No. 2020PC-110 orders, among other things, the 110: Temporary Restrictions following: 93

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) On Certain Events, o “Any work that is capable of being performed Gatherings, And Businesses; remotely (i.e., without the worker leaving his or her Rescission Of Executive home or place of residence) must be performed Orders 2020-69 And 2020-96 remotely.” o “Indoor social gatherings and events among persons not part of a single household are permitted, but may not exceed 10 people.”  The Executive Order also rescinds Executive Order No. 2020- 96 (see above). Executive Order No. 2020- 06/05/20  Executive Order No. 2020-115 orders, among other things, the 115: Temporary restrictions Brodsky following: on certain events, o Effective June 15, 2020, rescission of Executive Order gatherings, and businesses No. 2020-110 (see above) which “restricts the operation of facilities offering non-essential personal care services.” o “Work that can be performed remotely (i.e., without the worker leaving his or her home or place of residence) should be performed remotely.” o “Any business or operation that requires its employees to leave their home or place of residence for work is subject to the rules on workplace safeguards in Executive Order 2020-114 or any order that may Kiderfollow from it.” Executive Order No. 2020- 06/11/20 06/30/20  Executive Order No. 2020-118 reiterates the provisions of 118 Executive Order No. 2020-85 (see above), imposing a Temporary prohibition moratorium on evictions, and rescinds Executive Order No. against entry to premises for 2020-85, which was effective through June 11, 2020. the purpose of removing or  The Executive Order is effective immediately and through excluding a tenant or mobile June 30, 2020. home owner from their home; Rescission of PC Executive Order 2020-85 94

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order No. 2020- 06/18/20 07/16/20  Executive Order No. 2020-127 extends the state of emergency 127: Declaration of state of declaration responding to the COVID-19 pandemic through emergency and state of July 16, 2020. disaster related to the COVID-19 pandemic; Rescission of Executive Order 2020-99 Executive Order 06/26/20  Executive Order No. 2020-134 temporarily extends Executive No. 2020-134: Order No. 2020-118 (see above), imposing a moratorium on Eviction diversion program evictions, now effective through July 16, 2020. for COVID-19-related Brodsky Executive Order No. 2020-134 also rescinds Executive Order debtors; No. 2020-118, effective on July 16, 2020. Rescission of Executive  Additionally, among other things, Executive Order No. 2020- Order 2020-118 134 addresses the Eviction Diversion Program and eligibility for rental assistance payments. Executive Order 2020-151: 07/14/20 08/11/20  Executive Order No. 2020-151 extends the state of emergency Declaration of state of declaration responding to the COVID-19 pandemic. emergency and state of disaster related to the COVID-19 pandemic Executive Order 07/27/20 08/31/20  Executive Order 2020-151 rescinds Executive Order 2020-131 No. 2020-158 (see above) and re-issues the text of Executive Order 2020-131, Encouraging the use of extendedKider until August 31, 2020. electronic signatures and remote notarization, witnessing, and visitation during the COVID-19 pandemic; Rescission of Executive Order 2020-131 PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Directive 2020 - 08 08/04/20  Executive Directive 2020 – 08, addressed to all state department directors and autonomous agency heads, directs the following, among other things: o “Many departments and agencies administer licensing programs for individuals and businesses that offer services to the public. When interpreting a licensee’s obligation to demonstrate or maintain suitability for licensing, state department directors and autonomous agency heads must consider violations of law, including violations of relevant COVID-19 executive Brodsky orders and epidemic orders issued pursuant to section 2253 of the Public Health Code, as amended, MCL 333.2253 (‘epidemic orders’), as evidence of a lack of suitability for licensing, to the extent permitted by law.” Executive Order 2020-177: 09/03/20 10/01/20  Executive Order No. 2020-177 extends the state of emergency Declaration of state of declaration responding to the COVID-19 pandemic through emergency and state of October 1, 2020. disaster related to the COVID-19 pandemic Michigan / Frequently Asked Questions rev. 03/24/20  The Michigan Office of Consumer Finance (OCF) continues its Department of for Consumer Finance 2020 examinations but has moved towards off-site Insurance and Licensees and Registrants examinationsKider during the COVID-19 pandemic. Financial Services  “OCF is adjusting our internal operations as needed, to ensure (DIFS) uninterrupted availability to you and uninterrupted processing of examinations and licensing activities. Applications will continue to be processed, calls answered, examinations performed, and we will work to keep you informed of any changes. As of March 16, 2020, only off-site examination functions are being performed, with critical reviews which cannot be performedPC offsite being postponed to a later date. Conditions will continue to be monitored in 96

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) order to determine when on-site examination functions may resume. Rescheduling of full examinations is occurring on a case-by-case basis, with accommodations being made wherever possible and prudent.”  “OCF encourages licensees to work with affected consumers in addressing the impact and challenges resulting from COVID-19. Strategies to consider may include: o Waiving or reducing late fees. o Offering payment accommodations where appropriate. Brodsky o Adjusting or modifying terms on existing loans where possible and appropriate.” Frequently Asked Questions 03/27/20  The Michigan Office of Consumer Finance (OCF) published for Mortgage Loan FAQs addressed to MLOs affected by COVID-19. Originators  The guidance emphasizes that MLO remote work is permissible because the “Mortgage Loan Originator Licensing Act does not prohibit a licensed mortgage loan originator from working from home,” provided that consumer security obligations are fulfilled. Frequently Asked Questions Rev. 04/02/20  The Michigan Office of Consumer Finance (OCF) clarified, in for Consumer Finance their revised Consumer Finance Industry FAQs, that licensees Licensees and Registrants under an OCF-administered statute do not need to temporarilyKider suspend activities pursuant to the Governor’s Executive Order 2020-21 which required “suspension for activities not necessary to sustain or protect life.” Specifically, the OCF added: “Licensees and registrants under the Mortgage Brokers, Lenders and Servicers Licensing Act, Secondary Mortgage Loan Act, Mortgage Loan Originator Licensing Act, Regulatory Loan Act, Deferred Presentment Service Transaction Act, Consumer Financial Services Act, Debt Management Act, MoneyPC Transmission Services Act, Motor Vehicle Sales Finance Act, and Credit Card 97

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Arrangement Act are considered part of the financial services sector. Please review the Director’s Bulletin no. 2020-11- BT/CF/CU for further information.” Frequently Asked Questions Rev. 04/06/20  The Department revised the consumer finance industry FAQs for Consumer Finance to add the following question and answer: Licensees and Registrants o Q: “The guidance provided in Bulletin 2020-11- BT/CF/CU concerning the specific industries included within the term “financial services” as used in Executive Order 2020-21 includes inspectors. Is the activity of inspectors limited?” Brodsky o A: “Nothing exempts critical infrastructure workers from the requirements under Executive Order 2020-21 that any work must be completed remotely wherever possible. Where it is not possible to complete that work remotely, it may occur subject to all applicable conditions in Executive Order 2020-21, such as social distancing practices and other mitigation measures to protect workers and patrons. Inspectors are included under the term “financial services” only to the extent that a loan program or an existing purchase agreement requires an inspection by a qualified inspector before the transaction can be completed. Any inspection Kideractivity conducted must abide by all applicable conditions in Executive Order 2020-21, such as social distancing practices and other mitigation measures to protect workers and patrons. Additionally, nothing in the bulletin requires the use of an inspector in connection with a transaction or that an inspector accept an .” Bulletin 2020-11-BT/CF/CU 03/30/20  Bulletin 2020-11 provides guidance on the term “financial services” as used in ExecutivePC Order 2020-21, which “broadly prohibits in-person work with a narrow exception for critical 98

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) infrastructure workers . . . [which includes] some workers in the financial services sector . . . .”  “Consistent with Executive Order 2020-21, work is to be done remotely to the fullest extent possible, and in-person work is permitted only in accordance with social distancing and other requirements of the Executive Order for those conducting their jobs as critical infrastructure workers and those non- critical infrastructure workers designated to maintain minimum business operations.”  The Bulletin clarifies that “financial services” means, in part, Brodsky consumer financial service providers, which includes, for example, mortgage companies. Information on the 04/20/20  The Michigan Department of Insurance and Financial Services MiMortgage Relief published information on the “MiMortgage Relief Partnership Partnership,” in which participating financial institutions have agreed to assist affected residential mortgage loan borrowers by, at a minimum: (i) providing a 90-day grace period for all mortgage payments, (ii) waiving or refunding mortgage-related fees for at least 90 days for borrowers who reach an agreement with the financial institution, (iii) agreeing not to initiate any foreclosure sales or evictions for 60 days for borrowers who reach an agreement with the financialKider institution, (iv) refraining from reporting adverse credit scoring information for borrowers accessing relief who have reached an agreement with the financial institution, and (v) working with affected on borrowers on specific requests, concerns, or individual financial health (e.g., issues relating to escrow and tax insurance payments). NMLS COVID-19 Filing 04/23/20  The due date for completion of the following reports is Guidance extended by 30 days: o 2020 Q1 MortgagePC Call Report; o MCR Standard Financial Condition; 99

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o 2019 Q4 MSB Call Report; o 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Bulletin 2020-21-BT/CF/CU 04/30/20  Bulletin 2020-21 extends Bulletin 2020-11 for the period of time that Executive Order 2020-59 (or any subsequent Executive Order reaffirming or clarifying the measures in the Order) remains effective Bulletin 2020-23-BT/CF/CU 05/06/20  Bulletin 2020-23 supersedes Bulletin 2020-21 (see above).  The Bulletin reaffirms, clarifies, and extends the measures in Brodsky Bulletin 2020-11 (see above), in accordance with Executive Order 2020-70 (see above).  The sole purpose of the Bulletin is to provide guidance on the term “financial services,” as used in Executive Order 2020-70. The Bulletin defines the term to include the following: o Banks, credit unions, and consumer financial service providers (e.g., mortgage companies, money transmitters, payday lenders, consumer installment lenders, sales finance lenders, debt management companies, and pawnbrokers); and o Bond issuers.  The Bulletin, among other things, reiterates Executive Order 2020Kider-70’s designation of certain real-estate industry activities (e.g., real-estate brokers and agents) as permissible “resumed activity,” effective May 7, 2020, subject to certain conditions including social distancing requirements. The Bulletin highlights that “notaries who may perform work in the real- estate industry are regulated by the Michigan Secretary of State” and “should contact their respective regulators with any questions.” PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Memorandum: Safe Start 06/04/20  The memo, addressed to financial institutions, summarizes Best Practices – Financial the recommendations made by the DIFS’ advisory working Institutions group, “tasked with collecting input on best practices for financial institutions to safely re-open offices and for employees and the public to return to those offices.”  The recommendations, all purely advisory, include those related to administrative controls, access controls, social distancing, sanitation, hygiene, PPE, case monitoring, facility closure, Frequently Asked Questions 07/15/20  The Michigan DIFS FAQs for customers and borrowers for Consumer Finance Brodsky addresses, among other things, what to do if a borrower’s Customers and Borrowers lender or loan servicer has “reduced or shutdown their operations due to the coronavirus.”  The FAQs also emphasize that the “Office of Consumer Finance never advises borrowers to stop making their loan payments” and that questions regarding payments should be directed to the loan servicer. Bulletin 2020-42-BT/CF/CU 10/26/20  Bulletin 2020-42, (superseding Bulletins 2020-11-BT/CF/CU; (“Bulletin 2020-42) 2020-13-BT/CF/CU; and 2020-23-BT/CF/CU) requires regulated entities and individuals to comply with: o the Michigan Department of Health and Human Services’ emergency order issued October 9, 2020 Kider(Emergency Order), which, among other things, imposes worker protection requirements for businesses in the financial services industry subject to DIFS’ regulatory oversight; o the Michigan Occupational Safety and Health Administration’s Emergency Rules, issued on October 14, 2020 and entitled “Coronavirus Disease 2019 (Covid-19)” (Emergency Rules), which, among other things, establishedPC requirements employers in the financial services industry subject to DIFS’ regulatory 101

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) oversight, to control, prevent, and mitigate the spread of COVID-19 among employees; and o any other applicable law, rule, or regulation related to the public health emergency caused by the COVID-19 pandemic or other emergency issued or enacted at the federal, state, or local level.  The Bulletin also requires regulated entities and individuals to “remain apprised of and in compliance with new or amended laws intended to address the public health emergency caused by the COVID-19 pandemic that require Brodsky the entity or individual to take or refrain from taking certain actions or otherwise impact the entity or individual.” The Bulletin lists, as an example, PA 236 of 2020, which provides civil liability protections relating to the COVID-19 pandemic by “prohibiting an employer from taking certain actions against an employee who does not report to work under certain circumstances related to COVID-19, and prohibiting an employee from reporting to work under certain circumstances related to COVID-19).” Memorandum: Safe Start 10/28/20  The Memorandum sets forth the “best practice consensus” of Best Practices – Financial DIFS’s “advisory workgroup tasked with collecting input on Institutions best practices for financial institutions to safely re-open offices andKider for employees and the public to return to those offices.”  The best practices address: administrative controls (e.g., creating an exposure control plan, employee training), access controls (e.g., office plans for reducing congestion, employee health/exposure screening), social distancing (e.g., limiting physical spaces, staggering shifts, implementing visual cues), sanitation, hygiene, PPE, case monitoring (e.g., providing protocols for symptomatic employees, providing guidance to exposed employees, usingPC workplace tracing to mark clean spaces), facility monitoring (e.g., establishing a response place 102

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) for confirmed cases, conduct contact tracing investigation, effective employee communication). Minnesota / State 2020 MN HB 15 10/22/20  The Act temporarily authorizes, during and for 60 days after Legislature the expiration of the COVID-19 peacetime emergency declared by the governor, the requirement to appear personally for a notarial act to be deemed met when the notarial officer and the individual making the statement or executing the signature, whether acting on behalf of themselves or in a representative capacity, are not in the same location but are physically located within the state of Brodsky Minnesota and communicate via video conference in real time, subject to certain requirements. Minnesota / Office Emergency Executive Order 06/12/20  Executive Order 20-75 extends the COVID-19 Peacetime of the Governor 20-75 Extending the COVID- Emergency, initially declared in Executive Order 20-01 on 19 Peacetime Emergency March 13, 2020. Declared in Executive Order  The Executive Order extends the COVID-19 Peacetime 20-01 Emergency for 30-days—i.e., through July 13, 2020—pursuant to the Governor’s decision that extensions of the peacetime emergency should be limited to 30-day increments. Emergency Executive Order 07/13/20 08/12/20  Executive Order 20-78 extends the COVID-19 Peacetime 20-78 Extending the COVID- Emergency, initially declared in Executive Order 20-01 on 19 Peacetime Emergency March 13, 2020. Declared in Executive Order  TheKider Executive Order extends the COVID-19 Peacetime 20-01 Emergency for 30-days—i.e., through August 12, 2020— pursuant to the Governor’s decision that extensions of the peacetime emergency should be limited to 30-day increments. Emergency Executive Order 08/12/20 09/11/20  Executive Order 20-83 extends the declared peacetime 20-83: Extending the emergency in Minnesota, initially declared under Executive COVID-19 Peacetime Order 20-01 issued on March 13, 2020, through September 11, Emergency Declared in 2020. Executive Order 20-01 PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Emergency Executive Order 9/11/20 10/12/20  Executive Order 20-98 extends, through October 12, 2020, the 20-89: Extending the declaration of peacetime emergency, initially declared in COVID-19 Peacetime Executive Order 20-01 on March 13, 2020. Emergency Declared in Executive Order 20-01 Minnesota / Guidance to MN Regulated 03/16/20  If a loan company closes a branch, the company must inform Department of Loan Companies the Minnesota Commerce Department. Commerce o If the closure is temporary, the notification may be either via email or mail, and must also include a Guidance to Minnesota 03/27/20 schedule for when the company expects the branch to Licensed Originators and Brodsky reopen. Note, this schedule also must be Servicers (Companies and conspicuously posted on the branch’s front door. An Individuals) additional notification must be made if there is a change to the schedule for reopening. o If the closure is permanent, the company must file a surrender request through the NMLS. Guidance to Minnesota 03/18/20  Some branch employees may work from home if (1) the Licensed Non-Depository branch continues to offer and close loans, (2) loans are closed Financial Institutions under the address of the licensed branch, (3) consumers do not physically go to any unlicensed location for any part of the loan process, (4) no physical records are kept at the unlicensed location, and (5) the employee is able to maintain theKider company’s data security policies and standards.  The Financial Institutions Division is implementing a temporary telework policy until, at least, April 1, 2020. The Division recommends using the provided email address as a means of contact. Statement on Financial 3/20/20  This statement encourages financial institutions to make Institutions Working with efforts, including the following, to assist customers affected Customers/Members by the Coronavirus: Affected by the Coronavirus o “Waiving certain fees,PC such as: and Regulatory Assistance 104

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) - Automated teller machine (ATM) fees for customers and non-customers, - Overdraft fees, - Late payment fees on credit cards and other loans, and - Early withdrawal penalties on time deposits; o Increasing ATM daily cash withdrawal limits; o Easing restrictions on cashing out-of-state and non- customer checks; o Increasing credit card limits for creditworthy borrowers; and Brodsky o Offering payment accommodations, such as allowing borrowers to defer or skip some payments or extending the payment due date, which would avoid delinquencies and negative credit bureau reporting caused by COVID- 19-related disruptions.”  “Commerce will work with affected financial institutions to reduce burden when scheduling examinations or inspections.”  Financial institutions that have to temporarily close should notify the Department. NMLS State Agency 04/10/20  All Minnesota Department of Commerce personnel working Operating Status remotely. spreadsheet  “EmailsKider should be directed to the addresses listed on each of the relevant Checklists posted on the NMLS website.” Regulatory Guidance 20-09 03/30/20  The guidance is issued in response to the Commissioner of Commerce issuing an order granting licensees temporary extensions for certain deadlines.  The Commerce Department extended the deadline to file Annual Reports to April 30, 2020 for regulated lenders, among other licensees. PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Regulatory Guidance 20-34: 07/10/20  The guidance allows the Minnesota Department of Commerce Temporary Producer to “issue temporary producer licenses to applicants who meet Licensing Updates the requirements for resident licensure under Minn. Stat. § 60K, without requiring examination or the submission of fingerprints.”  The guidance outlines conditions for the temporary producer licenses, including that they are only valid for 180 days, and how to apply. Missouri / Informal regulator guidance  Missouri Division of Finance’s intention is to continue to Division of provide as normal services as possible to citizens and Finance Brodsky industry during this situation. NMLS State Agency 03/16/20  Only essential Missouri Division of Finance personnel are Operating Status working. spreadsheet  “Phone calls and emails will be taken as normal.”  “All licensing and examinations will continue as normal. The Division utilizes technology to review and streamline the licensing and examination process and will continue to do so as normal. On-site visits at this time are very limited and would only be used in extreme cases. Public access to the Division is not available at this time.” NMLS COVID-19 Filing 04/20/20  The due date for completion of the following reports is Guidance extended by 30 days: Kidero the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later due to COVID-19. Memorandum: Waiver of 05/01/20 06/15/20  The Missouri Division of Finance is temporarily waiving Notary Requirements certain statutory and regulation provisions requiring a notarized signature to be submitted to DOF. The provisions listed are those relevant to: banks and trust companies, savings and loan associations,PC consumer lending, mortgage licensing, and money transmitters. 106

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  “All such documents included with this request must continue to be signed before filing with DOF, which will then follow its established procedures for review and compliance. In the interim, the filing of ‘un-notarized,’ yet otherwise properly completed, documents shall be deemed in compliance with the law.” Division Guidance on the 05/12/20  The guidance responds to the Interagency Statement on Loan Interagency Statement on Modifications and Reporting for Financial Institutions Loan Modifications Working with Customers Affected by the Coronavirus, as revised on April 7, 2020. Brodsky The guidance states the Division of Finance’s intent not to “automatically adversely classify loans prudently modified” for the purpose of supporting borrowers that have been adversely impacted by the COVID-19 pandemic.  The guidance also (i) lists the DOF’s expectations for documentation on loans modified and (ii) lists the items for which the DOF expects evidence of Board review. Missouri / Extension Stay at Home 04/16/20 05/03/20  The Order extends the stay-at-home order for individuals Department of Order COVID-19 currently residing within Missouri through May 3, 2020. Health and Senior Services Mississippi / Memo to CF Licensees 03/14/20  The Department of Banking and Consumer Finance has stated Department of thatKider they will be available to assist industry and consumers Banking and via telephone and email. Consumer Finance MLO Interim Guidance 03/16/20  The Department is temporarily allowing “licensed mortgage loan originators to work from home, whether located in Mississippi or another state, even if the home is not a licensed branch,” subject to certain requirements, including a prohibition against allowing consumers to come into the home and specified data securityPC requirements.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS State Agency 03/31/20  “Please email [email protected] for the Mortgage Operating Status Division and [email protected] for the Consumer spreadsheet Division.” NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Brodsky Dec. 31, 2019 or later due to COVID-19. Mississippi / Executive Order No. 1473 04/17/20 04/20/20  Executive Order No. 1473, in addition to making certain Office of the clarifications, extends the Mississippi stay-at-home order Governor through 8am on April 27, 2020. Executive Order No. 1477 04/24/20 05/11/20  Executive Order No. 1477 implements a Safer at Home Order, (effective encouraging individuals, subject to exceptions (i.e., vulnerable 04/27/20) individuals still under a shelter-in-place order) to stay at home or their place of residence when not engaged in essential activities or essential travel (as defined under the Order).  Among other things, the Executive Order also prohibits evictions for residential premises, as well as public and privateKider social and non- essential gatherings to occur in groups of more than 10 people in close proximity in a single space. Montana / Office Directive Implementing 03/26/20 04/10/20  The Directive orders, among other things, for individuals to of the Governor Executive Orders 2-2020 and (effective stay at home or in their place of residence and for non- 3-2020 providing measures 03/28/20) essential businesses and operations to cease. to stay at home and designating certain essential functions Directive implementing 04/07/20 04/24/20  The Directive extends otherPC directives, including the March 26 Executive Orders 2-2020 and Stay-at-Home Directive, through April 24, 2020. 108

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) 3-2020 and extending certain Directives through April 24, 2020 Directive implementing 04/22/20  The Directive extends the Stay-at-Home Directive, subject to Executive Orders 2-2020 and exceptions, for individuals until April 26, 2020 and for non- 3-2020 and providing essential businesses until April 27, 2020. The Directive guidance for the phased implements a phrased reopening of Montana, subject to reopening of Montana and limitations. establishing conditions for  Except where specified in the Directive, the Directive is Phase One effective through the declared state of emergency. Governor Bullock Brodsky05/19/20  Governor Steve Bullock announced that Montana will move Announces Montana to (effective to Phase 2 of the Reopening the Big Sky plan on June 1. Enter Phase Two of 06/01/20) Reopening Plan on June 1st Montana / NMLS State Agency 03/16/20  All Montana Division of Banking and Financial Institutions Division of Operating Status personnel are working remotely. Banking and spreadsheet  The Division requests all communication be sent Financial electronically. Institutions Supervisory Memorandum 03/19/20  All Division office staff are working remotely and, therefore, on Operations During Novel will not be onsite to receive or process incoming mail. Written Coronavirus Situation correspondence should be sent via email or file transfer service.  CallingKider the office of the Division “will connect you with an administrative professional who will connect you with appropriate personnel.” Communication with BDFI 03/16/20  As of March 16, the Division mandated telework for office During Pandemic staff and has requested communication (including electronic documents) be made via telephone and email. NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 MortgagePC Call Report; o MCR Standard Financial Condition; and 109

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later due to COVID-19. DBFI Resources and Rev. 04/02/20  The Division is requiring the following data security Response to COVID-19 measures be followed: o “The licensed MLO must be able to access the licensed mortgage company’s secure origination system (including a cloud-based system) directly from any out-of-office device that mortgage loan officer uses, using a virtual private network (VPN) or other similar system that requires passwords or other forms of Brodsky authentication to access.” o “All security updates, patches, or other alterations to the device's security must be maintained.” o “Physical business records are maintained at the books and records location that is on file with the Division.”  The Division is extending the guidance provided for MLOs “to other non-depository licensees and their employees” and recommends reaching out with questions, if any, to them at [email protected].  The Division has stated that it “is sensitive” to the COVID-19 challenges and “will be responsive to reviewing extension requests and other appropriate forms of regulatory relief arisingKider from service and staff disruptions related to COVID- 19.”  The Division is following the NMLS COVID-19 policy changes regarding certain report filing. Technology-Based 04/02/20  The Division released instructions on notarizing a document Notarizations online with respect to the two types of technology-based notarizations available to Montana notaries: remote online notarization and remote notarization.PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) FAQs Regarding Executive 04/07/20  The Division published FAQs in response to the new Orders 2-2020 and 3-2020 limitation on foreclosures, effective from March 31 through Providing Measures to Limit April 24,2020, unless extended by the Governor if necessary. Foreclosures  The FAQs address (i) the types of residential real property covered under the limitation; (ii) exemptions to the prohibition on foreclosures; (iii) the prohibition on late fees charged on trust indentures or mortgages; and (iv) how banks, credit unions, and residential mortgage servicers should manage the mandated reporting to the credit bureaus for covered loans. Division FAQs on the Brodsky06/25/20  The guidance provides general regulatory information and Montana Loan Deferment (last rev. FAQs concerning the Montana Loan Deferment Program, in Program 06/24/20) which the State of Montana has partnered with Montana banks, credit unions, and lending institutions to provide relief to consumers during the COVID-19 crisis.  The guidance, among other things, addresses (i) the Division’s position on nonaccruals, (ii) disclosures, (iii) fair lending, (iv) the ECOA Regulation B adverse action notice, (v) and flood requirements. Montana / Notice of Adoption of 04/02/20  The Montana Department of Administration’s new temporary Department of Temporary Emergency emergency rule responds, in part, to the concerns received Administration Rule: “from banks and credit unions regarding the difficulty of In the matter of the holdingKider an in-person annual meeting while complying with adoption of Temporary the stay-at-home directive and social distancing Emergency Rule I pertaining requirements.” to annual meetings held by  The Department issued the following temporary emergency banks and credit unions rule: during the COVID-19 o “NEW RULE I VIRTUAL ANNUAL MEETINGS pandemic HELD BY BANKS AND CREDIT UNIONS DURING DECLARED EMERGENCY OR DISASTER RELATED TO COVID-19 PANDEMICPC (1) This rule is only effective when there has been a declaration by the 111

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) governor of an emergency or disaster related to the COVID-19 pandemic. (2) During the period of a declaration by the governor of an emergency or disaster related to the COVID-19 pandemic, a bank or credit union may hold its annual meeting in the form of a virtual meeting. To satisfy the bank's or credit union's annual meeting requirement, a virtual meeting must be live, allow electronic or telephonic participation in the meeting in real-time, and provide simultaneous audio transmission of the meeting.” Nebraska / Office Executive Order No. 20-13: Brodsky04/01/20  The Executive Order waives specific Nebraska statutes of the Governor Coronavirus – Accelerating “pertaining to the Online Notary Public Act and laws and Online Notary Access and regulations governing financial institutions that are under Financial Institutions supervision of the Nebraska Department of Banking and Regulatory Flexibility Finance.” o The Online Notary Public Act’s July 1, 2020 operative date is waived “so that the Secretary of State can immediately commence implementation of the Act.” o The following requirements are also waived until 30 days after the COVID-19 state of emergency is lifted: . The required submission of the annual Directors’ Examination (within 90 days of the Kiderend of the calendar year or 90 days of the examination completion); . The requirement that bank directors or an accountant must be “physically present in order to carry out the regulation to count cash”; . The required submission of examination report copies by a board of directors or an accountant; and PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) . The requirement that “the Supervisory Committee or an accountant to file two copies of its report with the Department of Banking within 90 days from the starting date of the audit.” o The requirement for annual calendar examinations of installment loan companies’ books and records is waived, and the Department will accomplish such examinations as soon as practicable.  Effective until 30 days after the COVID-19 state of emergency Brodsky is lifted, “only one electronic or paper original of an application mandated by Title 49 Nebraska Administrative Code Chapter 2 § 005.02 needs to be filed, and may have an electronic or manual signature.” Nebraska / Mortgage Banker and 03/12/20 12/31/20  The Nebraska Department of Banking and Finance is Department of Mortgage Loan Originator temporarily allowing licensed, and sponsored, mortgage loan Banking and Guidance on Temporary originators to work from an unlicensed branch, including a Finance Branch Relocations home office, subject to certain requirements, including a prohibition against allowing consumers to come into the home, certain security requirements, and approval from the Department using a form provided by the Department. NMLS State Agency 03/23/20 04/30/20  Preferred methods of contact: [email protected], or Operating Status callKider 402-471-2171. spreadsheet NDBF Financial Institution 03/25/20 04/24/20  “The Nebraska Department of Banking and Finance Examination Posture (Department) will temporarily cease all regular examination activity effective March 25, 2020, except where the examination work is critical to safety and soundness, consumer protection, or is required to address an urgent or immediate need.”  “The institution may electPC to move forward with a Department examination if it has previously provided a 113

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) majority of the requested information; however, the determination to proceed will be left up to the institution.”  This announcement applies to all Nebraska State charted, licensed, and supervised depository and non-depository financial institutions NMLS COVID-19 Filing 04/16/20  The due date for completion of the following reports is Guidance extended by 30 days: o 2020 Q1 Mortgage Call Report; o MCR Standard Financial Condition; o 2019 Q4 MSB Call Report; Brodsky o 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. NDBF Financial Institution 04/27/20 05/15/20  The Department updated its announcement with regard to Examination Posture 4-27-20 the temporary closure of all regular examination activities to update extend to closure until May 15, 2020.  “The Department will commence moving forward slowly commencing institution contact regarding upcoming examinations, pre-examination requests, and discussions enabling offsite examinations beginning May 18th. An offsite examination is defined as an examination in which examiners for all or a majority of the examination are not physically in theKider financial institution.”  Offsite examinations will resume on June 1, 2020, conducted predominately using remote access resources.  This announcement applies to all Nebraska State charted, licensed, and supervised depository and non-depository financial institutions Nebraska Department of 05/18/20  The NDBF announced that they will move forward with Banking and Finance financial institutions examinations (non-depository & (NDBF) depository) beginning on PCJune 1, 2020, using certain specified Examination Practices 114

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) procedures (e.g., conducting solely offsite exams, digital loan documentation). Nevada / Office of Declaration of Emergency 04/29/20 05/15/20  Declaration of Emergency 16 extends the majority of the Stay- the Governor 16 at-Home measures and eases some restrictions (e.g., authorizing curbside pickup for all retail businesses, relaxing outdoor activity restrictions).  Guidance on the Declaration of Emergency 16 is linked here. Declaration of Emergency 05/07/20  Executive Order 018 implements phase one of Nevada’s Directive 018 reopening plan.  The “Nevada United: Roadmap to Recovery” plan is linked Brodsky here. Industry-Specific Guidance 05/08/20  As part of the Nevada Health Response to COVID-19, the for Phase 1 Reopening Nevada Governor's Office and the Nevada Department of Health and Human Services published industry-specific guidance for Nevada’s phase I reopening.  The guidance addressed, among other industries, (i) banking and financial services and (ii) general office environments, and (iii) real estate / leasing. With respect to each industry, the guidance outlines both mandatory and, when applicable, recommended best practices.  With respect to the real estate / leasing industry, the guidance: o reiterates the directive of Section 6 of Emergency KiderDirective 013—i.e., (i) prohibiting, until May 15, 2020, “open house showings, and in-person showings of single family and multi-family residences currently occupied by renters of real estate on the market for sale; and (ii) requiring “that real estate professionals engaged in real estate sales during the state of emergency shall adopt precautionary measures and COVID-19 risk mitigation practices to minimize the risk of spreading thePC disease and are encouraged to

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) avoid in-person transactions and services to the extent practicable.” o highlights that Section 6 of Emergency Directive 013 “does not prohibit the use of existing three- dimensional (3-D) interactive property scans, virtual tours, and virtual staging to showcase a property, and it allows, but does not require, the tenant to agree to provide photos, videos, or other virtual access to the property owners for this use.” Gov. Sisolak declares State 05/11/20  Governor Steve Sisolak declared a state of fiscal emergency in of Fiscal Emergency due to Brodsky response to the COVID-19 crisis, allowing the Governor and COVID19 pandemic the Interim Finance Committee authority to transfer money from the Account to Stabilize the Operation of the State Government to the general fund. Industry-Specific Guidance Rev. 05/15/20  As part of the Nevada Health Response to COVID-19, the for Phase 1 Reopening – Nevada Governor's Office and the Nevada Department of UPATED Health and Human Services updated its industry-specific guidance for Nevada’s phase I reopening (see above). The updates, however, did not impact or revise the guidance specific to (i) banking and financial services and (ii) general office environments, and (iii) real estate / leasing.  Please note, however, that the updated guidance does not addressKider the May 15, 2020 expiration date of Section 6 of Emergency Directive 013, retaining the language addressing this provision in the revised guidance Nevada United 05/20/20  The Nevada Governor's Office and the Nevada Department of Health and Human Services announced that Nevada is currently in Phase One of the Nevada United: Roadmap to Recovery Plan. Governor Sisolak Releases 05/25/20  Governor Steve Sisolak announced that Phase 2 of the Prepared Remarks, (effective “Nevada United: RoadmapPC to Recovery” reopening plan (see 05/29/20) above) will begin on Friday, May 29, 2020. 116

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Guidance for Phase 2 Reopening Declaration of Emergency 05/28/20 06/30/20  Directive 021 implements Phase 2 of the “Nevada United: Directive 021: Phase Two Roadmap to Recovery” reopening plan. Reopening Plan  The Directive, among other things, includes certain recommended protocols that employers and employees are strongly encouraged to incorporate into their business operations, including, for example, continuing to telework whenever possible and feasible.  The Directive also makes certain orders, including, for Brodsky example, the following: o “All employers must take proactive measures to ensure compliance with the social distancing and sanitation guidelines. All employers shall continue to require employees who interact with the public to wear face coverings, to the maximum extent possible, and shall abide by all other guidelines promulgated by NV OSHA.” o “All businesses must adopt measures that meet or exceed the standards promulgated by NV OSHA to minimize the risk of spread of COVID-19. All businesses are encouraged to permit their employees Kiderto work from home to the maximum extent practicable.”  The Phase Two Reopening: General Guidance is linked here. COVID-19 Declaration of 06/25/20 08/31/20  Among other things, Directive 025 amends Directive 008, Emergency Directive 025 which imposed a moratorium on commercial eviction and foreclosure actions currently being adjudicated; the amendments provide for lifting the moratorium in phases.  Further, Directive 025 rescinds Directive 008 beginning on September 1, 2020. PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  Additional information regarding Directive 025, including FAQs for landlords and tenants, as well as a reference chart for the phases implementing the lifting of the moratorium, are available here. Declaration of Emergency 06/29/20 07/31/20  Among other things, Declaration of Emergency Directive 026 Directive 026 extends Directive 021, Phase Two of the Nevada United: Roadmap to Recovery plan (see above), through July 31, 2020. Declaration of Emergency 07/31/20  Declaration of Emergency Directive 029 orders, among other Directive 029 things: o that the Nevada United: Roadmap to Recovery plan be Brodsky reaffirmed and that the “[r]estrictions imposed by county government or local municipalities may exceed the standards imposed by Declaration of Emergency Directives and any state or federal guidelines to the extent reasonable, or set forth under the LEAP guidelines, but in no case shall such local guidelines be more permissive than the provisions of this Directive and the disease management plans it authorizes”; and o an extension, for the duration of the current state of emergency, “[a]ll directives promulgated pursuant to the March 12, 2020 Declaration of Emergency or subsections thereof set to expire on July 31, 2020.” Declaration of Emergency 08/31/20 10/13/20  DirectiveKider 031 terminates Directive 008 and Directive 025 (see Directive 031 above) and, effective through October 14, 2020, prohibits the initiation of a nonpayment of rent summary eviction action by service of a pay or quit notice.  Frequently Asked Questions concerning Directive 031 (guidance for tenants and landlords) are available here. Press Release: As State 10/13/20  The press release reminds Nevadans of the October 15, 2020, Evictions Moratorium Lifts, expiration of Nevada’s statewide eviction moratorium and State Reminds reiterates the continuation,PC through December 2020, of the CDC Order prohibiting certain evictions. 118

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Nevadans of Ongoing  The CDC declaration and FAQs are available here. Federal Rental Protections, Resources During Pandemic Nevada / Division Provisional Guidance – 03/13/20 05/31/20  The Nevada Department of Business and Industry, Division of Mortgage Temporarily Working from of Mortgage Lending is temporarily allowing licensed MLOs Lending Home to work from home, even if unlicensed. NMLS State Agency 03/18/20 04/03/20  Essential functions of the Division continues to be completed Operating Status remotely, but with extended time frames. spreadsheet  “For licensing matters: [email protected]. For anything else: [email protected]. Phone 702-486- Brodsky 0782....leave a VM and the Division will return the call.” Mortgage Servicer COVID- 03/27/20  “In aligning with federal government, Division urges 19 Guidance Mortgage Servicers and Mortgage Companies to assist Nevadans by considering following actions: o As of the mortgage payment due date - 60 days mortgage payment forbearance. o No reporting of late payments to major credit reporting agencies for period of 60 days. o Regarding current loan modifications – provide options for additional 60 days grace period to address modifications and refrain from allowing COVID-19 issues harming current modification efforts. Kidero Waiving of late payment fees and any transactional fees for period of 60 days. o Refrain from foreclosures for period of 60 days. o If office closures occur, ensure that consumers are provided information and/or alternative services online so that the mortgage servicing functions are operational. o Inform, educate, and advise consumers via online platforms, email, telephone,PC mobile applications and etc. 119

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  Ensure security of data and adequate supervision of processes in accordance to applicable state and federal laws and company disaster plans.” Mortgage Servicer COVID- Rev. 03/20/20  The memorandum regarding COVID-19 guidance for 19 Guidance - UPDATED mortgage servicers (see above) has been amended “to align with the most recent Directive 008, Governor Sisolak, Attorney General Ford, State Treasurer Conine announced housing stability measures amid COVID-19 public health crisis dated 3-29- 2020.”  The amendments modify the actions that the Division urges Brodsky mortgage servicers and mortgage companies to take to assist Nevadans; each amendment revises the number of days at issue from 60 days to 90 days. o The amendments are as follows: . “As of the mortgage payment due date – 90 days mortgage payment forbearance. . No reporting of late payments to major credit reporting agencies for period of 90 days. . Regarding current loan modifications – provide options for additional 90 days grace period to address modifications and refrain from allowing COVID-19 issues harming Kidercurrent modification efforts. • Waiving of late payment fees and any transactional fees for period of 90 days. . Refrain from foreclosures for period of 90 days.” NMLS COVID-19 Filing 04/03/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR StandardPC Financial Condition; and

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Extended Provisional 05/18/20 08/31/20  The Nevada Mortgage Lending Division extended the Guidance -Temporarily previously issued guidance regarding temporary remote Working from Home work for licensed mortgage companies and their sponsored MLOs (see above). The guidance is now extended until August 31, 2020. Extended Provisional 08/21/20 12/31/20  The Nevada Mortgage Lending Division extended the Guidance – Temporarily previously issued guidance regarding temporary remote Working from Home work for licensed mortgage companies and their sponsored Brodsky MLOs (see above). The guidance is now extended until December 31, 2020. New Hampshire / Emergency Order #40 05/01/20 05/31/20  Emergency Order #40 extends the Stay-at-Home Order. Office of the Pursuant to Executive Order  Exhibit A to Executive Order #40 addresses, among other Governor 2020-04 as extended by things, real estate transactions, agents, and brokers, providing Executive Orders 2020-05 guidance, including, for example: and 2020-08: An order o The following may take place in-place if subject to extending and modifying appropriate social distancing measures: real estate Emergency Order #17 closings, property inspections, property appraisals, (Closure of non-essential property showings (made by appointment), meetings businesses and requiring between brokers/agents and prospective or current Granite Staters to stay at clients. home) Kidero Open houses are impermissible. Veto of 2020 NH HB 1247 07/10/20  New Hampshire Governor Christopher T. Sununu vetoed 2020 NH HB 1247, which would have created duty of good faith and fair dealing for mortgage lenders and prevented landlords from taking possessory actions for nonpayment of rent during the novel the COVID-19 emergency.  Governor Sununu stated in a veto message, among other things, “We must remember that property owners have also struggled throughout the PCCOVID-19 pandemic. Small property owners who rent 10 units or fewer account for 90% 121

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) of rental units in New Hampshire. They too have financial obligations that must be met, including mortgages, taxes and utilities.” New Hampshire / Responding to the Impacts  Pursuant to the New Hampshire statutes, MLOs may work Banking of the Novel Coronavirus from home or another alternative work location, which is now Department 2019 (COVID-19) exempt from the statutory requirement that the alternative location be within 100 miles of a supervisory office, subject to certain requirements, including security requirements. NMLS State Agency 03/18/20  “Communicating by e-mail is the preferred method of Operating Status contact. Questions can be sent spreadsheet Brodsky to [email protected] and if not a licensing question the e-mail will be forwarded to someone that can assist with the question.” FAQs on Mortgage 03/31/20  This guidance reiterates the prohibition on foreclosures and foreclosures During the forbearance relief by both state and federal governments. COVID-19 Pandemic NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; and o the MCR Standard Financial Condition.  Regarding the annual financial statement, the New Hampshire Banking Department is allowing companies to uploadKider unaudited statements. Agency homepage 04/03/20  “Financial institutions are considered an essential business and remain open during the stay-at-home order. Please visit your financial institution’s website regarding changes in branch hours and branch closures. Many financial institutions have temporarily closed their lobbies but banking services are available through the drive-thru, ATM, or by appointment. View the list of COVID-19PC temporary branch closures.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Guidance on Paycheck 04/03/20  The guidance states and explains that the loans made under Protection Program and the the Paycheck Protection Program, established under Section Legal Lending Limit 1102 of the CARES Act, are exempt from the New Hampshire statutory legal lending limit. Agency Homepage 05/28/20  “In light of ongoing COVID-19 concerns and for the safety of the public and our employees, the New Hampshire Banking Department (“Department”) is trying to minimize visits to the Department. Our staff is making every effort to accommodate your needs online and by phone. If you need assistance, the Department can be reached at 603-271-3561. Department Brodsky phones are staffed Monday through Friday, 8:00 a.m. to 4:30 p.m. You can also reach us by email at [email protected].” Reopening Branches and 05/28/20  The guidance concerns the reopening of branches and other Other Financial Institution financial institution (i.e., banks and credit unions) offices Offices Previously Closed previously closed due to the COVID019 pandemic. Due to the COVID-19  The guidance applies to the reopening of offices that were Pandemic temporarily closed due to the pandemic and outlines the steps necessary to reopen (i.e., a notification email to the Department with specified information). New Jersey / NMLS State Agency 03/18/20  On a daily basis, limited, essential New Jersey Department of Department of Operating Status Banking and Insurance Office of the Commissioner personnel Banking and spreadsheet willKider be in the main office. “Email is the preferred method of Insurance communication. Please email all documents [email protected] or the assigned reviewer rather than mailing them.”  “For licensing inquiries or work from home requests per NJ Bulletin 20-06 please email Daniel [email protected] or Howard [email protected]. For inquiries about mortgage loan originator PClicense applications please email Regina [email protected].” 123

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Disruption Resulting from 03/19/20  The Department encourages the regulated entities/individuals COVID-19 of the banking division to take actions (consistent with safe- and-sound banking practices), including: relaxing due dates for loan payments, extending grace periods, modifying terms on existing loans, easing credit card limits, extending new credit, waiving late fees and other fees, allowing customers to defer or skip payments, and delaying the submission of delinquency notices to credit bureaus. COVID-19 Matters 03/19/20 Until  The Department will expedite, as appropriate, any request to further provide more convenient availability of services in affected Brodskynotice communities where operational challenges persist.  The Department also reminds licensees to provide prompt notice to the Department regarding changes to branch hours.  All notices, inquiries, correspondence, and applications must be submitted via email (not by courier, overnight, mail, or fax). No Action Position 03/19/20 04/30/20  With submission of specified materials, individuals working Regarding Temporarily for OCF licensees currently licensed, or authorized to operate, Working From Home Due in NJ may temporarily work from home. to COVID-19 o Required materials include: (1) a list of all individuals working on behalf of the OCF licensee seeking no- action dispensation; (2) a certification by the OCF Kiderlicensee that the work-from-home individuals have a reason related to the COVID-19 outbreak for working from home, and have informed the OCF licensee; and (3) a certification by the OCF licensee that the location(s) of the work-from-home employee(s) will maintain the consumer’s right to privacy. Press Release: Governor 03/28/20  Governor Murphy announced a new initiative in which Murphy Announces financial institutions commit to provide mortgage forbearance Mortgage Payment Relief, and financial protections forPC New Jersey residents facing Financial Protections for economic hardship due to the COVID-19 emergency. 124

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) New Jerseyans Facing  Relief provided by the financial institutions to borrowers Economic Hardship as a impacted by COVID-19 under this initiative includes: Result of COVID-19 o Mortgage payment forbearances for a period up to 90 days; o Derogatory tradelines (e.g., late payments) will not be reported by the financial institution to credit reporting agencies; o A 60-day minimum moratorium on financial institutions imitating foreclosure sales or evictions; and Brodsky o Waiver or refunds for a minimum of 90 days for, at least, mortgage-related late fees and other fees (e.g., early CD withdrawals). COVID-19 and Residential 3/28/20  New Jersey residents struggling with the COVID-19 crisis Mortgage Relief may be eligible for the following residential mortgage relief: o 90-day grace period for all mortgage payments; o Relief from fees and charges for 90 days; o No new foreclosures for 60 days; and o No credit score changes for accessing relief.  To apply for mortgage relief and/or forbearance, individuals must contact their mortgage servicer, with whom the terms of a forbearance (e.g., length of forbearance) will be agreed.  FinancialKider institutions may report a forbearance but not derogatory information to credit reporting agencies. Agency Homepage 3/28/20  Although the Department’s buildings are closed to visitors, many of the Department’s employees are working remotely and the Department remains open for business. Bulletin 20-09 - No Action 03/30/20  This bulletin states the Department’s intent to provide Position Regarding Potential regulatory assistance to institutions affected by COVID-19, Disruptions Due to COVID- subject to the Department’s supervision. 19  “Real estate prelicensure coursesPC may be taught in an on-line format, such as in a webinar, a virtual classroom, or by video 125

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) conferencing. Persons seeking to teach these courses online should direct questions by email to Gwendolyn Cobb, Supervisor of Licensing and Education, at [email protected]. Courses must still meet the regulatory requirements regarding length and subject matter.”  To the extent that the New Jersey Executive Order No 103 is in effect, the Department is relaxing the following requirements: “applicants must pass the licensure test within one year of passing a prelicensure course” and “applications Brodsky for licensure must be submitted within one year following the date an individual passes the real estate prelicensure course.” o When either of the above requirements are relaxed, the Department may request additional information as part of the application evaluation.  A Notice of Rule Suspension was issued as an emergency adoption of temporary rule suspension for the above rules. Bulletin No. 20-15: 90-Day 04/10/20  Bulletins No. 20-15 and No. 20-17 were both issued in Grace Period for Property response to Executive Order No. 123, issued on April 9, 2020. and Casualty Insurance  The Department directs all licensed property and casualty Premium Payments Due to insurance carriers (in Bulletin No. 20-15) and all premium the Disruption Caused by finance companies licensed under the Insurance Premium COVID-19 FinanceKider Company Act (in Bulletin No. 20-17) to provide their Bulletin No. 20-17: 90-Day 04/10/20 insureds/clients who may be experiencing a COVID-19- Grace Period to Clients of related financial hardship with a 90-day grace period to pay Insurance Premium Finance for “insurance premiums so that insurance policies are not Companies Due to the cancelled for nonpayment of premium during this Disruption Caused by challenging time due to circumstances beyond the control of COVID-19 the insured.”  “A policyholder may elect this 90- day emergency grace period to begin retroactivelyPC on April 1, 2020 or opt for the grace period to begin on May 1, 2020.” 126

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The Bulletins directs insurers and insurance premium finance companies, during this 90-day period, to: (i) not cancel any insurance policy for nonpayment; (ii) waive late fees and charges otherwise due, (iii) not report late payments to credit rating agencies, (iv) allow premiums due but unpaid to be paid over a repayment period; (v) ensure future premium calculations do not consider late payments during this period; (vi) post information about the grace period on its website; (vii) provide policyholders and submit to the Department a written description of the grace period terms; and (viii) ensure Brodsky that licensees who accept premium payments on behalf of insurers “take steps to ensure that customers able to make payments have the ability to make prompt insurance payments through alternate methods of payment” (e.g., online payments). Bulletin 20-17 Frequently 04/23/20  The Bulletin 20-17 FAQs expand on Bulletin 20-17’s grant of a Asked Questions 90-day grace period to clients of insurance premium finance companies due to disruptions caused by COVID-19.  The FAQs, among other things, clarify the following: (i) Bulletin 20-17 does not apply to premium finance agreements entered into after March 1, 2020; (ii) the Bulletin requires an insured to “opt in” to be afforded the relief; (iii) the reference inKider the Bulletin to an “insurance carrier” was intended to mean a “premium finance company; and (iv) what steps the insurance premium finance company should take if the borrower fails to make the installment payment after the mandated grace period. Bulletin 20-18 Extension of 04/23/20  Bulletin 20-18 extends the deadline for license and registration Mortgage Servicer License applications under the Mortgage Servicers Licensing Act, Application and RMLA- originally set as April 13, 2020 by Bulletin No. 19-13, issued on Licensed Mortgage Servicer December 23, 2019. PC Registration Deadlines 127

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The application deadline for mortgage servicer licenses and RMLA-licensed mortgage servicer registration is extended to June 12, 2020. Bulletin No. 20-20: 05/01/20  Executive Order No. 20-20 grants, for this licensing term only, Extension of Insurance a three-month extension for insurance producer licenses Producer License Terms and expiring on or between March 31, 2020 and June 30, 2020. Waiver of Independent o E.g., an insurance producer license expiring on May Monitor for Continuing 31, 2020 will instead expire on August 31, 2020 but will Education Courses in be due for renewal, for the next licensing term, by May Response To Covid-19 31, 2022. Brodsky o E.g., an insurance producer license expiring on April 30, 2020 will instead expire on July 31, 2020 but will be due for renewal, for the next licensing term, by April 30, 2022.  The Executive Order also waives the requirement, for self- study courses taken from March 9, 2020 through June 30, 2020 that the course culminates in a monitored exam. Bulletin No. 20-21: 05/01/20  Bulletin No. 20-21 announces the New Jersey Department of Temporary Insurance Banking and Insurance’s decision “to issue temporary Producer License producer licenses to those qualifying individuals who wish to become New Jersey resident insurance producers.” The decision comes as a response to the current suspension of insuranceKider producer licensing exams (resulting from closure of all producer examination testing centers in New Jersey).  With regard to the temporary insurance producer license, the Bulletin outlines (i) the qualifications of applicants, (ii) application procedures, (iii) application timelines, (iv) terms and conditions for sponsoring and temporary producer licensees, and (v) procedures available for becoming fully licensed insurance producers after the issuance of the temporary license. PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The temporary insurance producer license will be available only for the duration of the declared state of emergency and public health emergency. Bulletin No. 20-23: 05/12/20  Bulletin No. 20-23 extends the filing deadline for certain Extension of Deadline For licensees’ annual report. Certain Division of Banking  Certain licensees, including insurance premium finance Regulated Entities and companies, whose annual report filing deadline is April 1, Individuals to File Annual 2020 are granted an extension to June 1, 2020 with respect to Reports in Response to this annual report only. COVID-19  “Mortgage lenders and mortgage brokers who are required to Brodsky file an annual report on or before May 1, 2020, are also granted an extension to June 1, 2020 for this annual report only. For the next annual report, mortgage lenders and mortgage brokers must file their annual report by May 1, 2021.” Bulletin No. 20-26: 05/28/20  “This bulletin extends the Department’s no-action position Extension of No Action [Bulletin No. 20-06 (see above)] for the duration of the public Position Regarding health emergency declared in EO 103 as currently extended Temporarily through EO 119 and EO 138, and for any future extensions of Working from Home Due to the public health emergency declared in EO 103.” COVID-19 Bulletin No. 20-23 FAQs 06/25/20  New Jersey DOB published FAQs concerning Bulletin 20-23 (Kidersee above), which extended the filing deadline for the annual report of certain licensees, including mortgage brokers and lenders.  Although Bulletin 20-23 provides for a June 1, 2020 extended deadline, the FAQs allow for a “grace period until August 1, 2020” for licensees who have yet to file.  The FAQs, among other things, also provide for a $100 fine per day in the event a licensee files the report past August 1, 2020. PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) New Jersey / Executive Order No. 119 04/07/20  Executive Order No. 119 extends the public health emergency Office of the (declared in Executive Order No. 103 on March 9, 2020), Governor pursuant to the Emergency Health Powers Act (EHPA), under which the emergency would have expired after 30 days if not renewed. Executive Order 123 04/09/20  Executive Order No. 123 extends grace periods during which certain insurance companies cannot cancel policies for nonpayment of premiums. Governor Murphy Takes 04/14/20  Governor Murphy signed into law, among other bills, A- Action on Legislation 3903/S-2336 to allow “remote notarial acts during Public Brodsky Health Emergency and State of Emergency declared by Governor in Executive Order 103 of 2020.” Executive Order No. 127 04/14/20  Executive Order No. 127 extends certain deadlines for state agency rulemaking until 90 days after the end of the public health emergency. Extended deadlines include, among others: o the expiration date for notices of rule proposals; o the deadline for an “Executive Branch department or agency to act on any currently pending petition for rulemaking or on any petition for rulemaking filed during the Public Health Emergency”; and o the expiration date of any rule (including any emergency rule) scheduled to expire either during the Kiderpublic health emergency or within 90 days after the end of the emergency. Governor Murphy 04/16/20  “Governor Phil Murphy today announced that the New Announces Suspension of Jersey Housing and Mortgage Finance Agency has Rent Increases at all unanimously voted to suspend rent increases at all eligible NJHMFA-Regulated properties within the Agency’s portfolio, which includes Properties 36,000 rental units across the state.”  “The suspension of rent increases will remain in place until the termination of ExecutivePC Order 103. Thereafter, eligible properties in the Agency’s portfolio seeking rent increases of 130

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) up to 1.4% may do so only after 30-day notice is provided to NJHMFA and residents. Any request in excess of this amount must first be reviewed and approved by NJHMFA staff. “  Additional program details are linked here. Executive Order No. 128 04/24/20  Executive Order No. 128 allows tenants to use their to offset rent.  The Executive Order remains in effect until 60 days after the end of the Public Health Emergency (established by Executive Order No. 103). Governor Murphy 04/27/20  Governor Murphy announced New Jersey’s recovery plan, Announces “The Road Back: Brodsky “The Road Back: Restoring Economic Health Through Public Restoring Economic Health Health.” Through Public Health”  “Governor Murphy’s stay-at-home Executive Order, which has been in effect since March 21st, will remain in effect in its entirety until further notice. The following six principles and key metrics will guide the process for lifting restrictions and restoring New Jersey’s economic health through public health.” o Principle 1: Demonstrate Sustained Reductions in New COVID-19 Cases and Hospitalizations o Principle 2: Expand Testing Capacity o Principle 3: Implement Robust Contact Tracing Kidero Principle 4: Secure Safe Places and Resources for Isolation and Quarantine o Principle 5: Execute a Responsible Economic Restart o Principle 6: Ensure New Jersey’s Resiliency Executive Order No. 130 04/28/20  Executive Order No. 130 allows municipalities to extend the grace period for the fourth-quarter property taxes to June 1, provided that such municipalities may not accelerate tax sale with respect to the installment for payment of the fourth- quarter property taxes. PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Governor Murphy Unveils 05/18/20  Governor Phil Murphey announced a three-stage plan for Multi-Stage Approach to reopening New Jersey’s economy. Execute a Responsible and Strategic Restart of New Jersey’s Economy Executive Order No. 151 06/04/20  Executive Order No. 151 extends the public health emergency, pursuant to the Emergency Health Powers Act (which requires that all declared public health emergencies expire after 30 days unless renewed). Executive Order No. 162 07/02/20  Executive Order No. 162 extends the public health emergency, Brodsky pursuant to the Emergency Health Powers Act (which requires that all declared public health emergencies expire after 30 days unless renewed). Executive Order No. 171 08/01/20  Executive Order No. 162 extends the public health emergency, pursuant to the Emergency Health Powers Act (which requires that all declared public health emergencies expire after 30 days unless renewed). Executive Order No. 180 08/27/20  Executive Order No. 162 extends the public health emergency, pursuant to the Emergency Health Powers Act (which requires that all declared public health emergencies expire after 30 days unless renewed). New Jersey / State 2020 NJ SR 64 04/13/20  “This resolution respectfully urges financial institutions to Legislature waiveKider bank fees and suspend credit card penalties, late fees, and interest payments for the duration of the coronavirus disease 2019 pandemic. These actions will assist employees and small business owners who have faced economic hardships as a result of social distancing and the Governor's Executive Order 107 and other enforced stay-at-home orders.” 2020 NJ AB 3903 04/14/20  New Jersey Assembly Bill No. 3903, among other things, authorizes, a notary public or an officer authorized to take oaths, affirmations, affidavits,PC or acknowledgements to perform notarial acts remotely during the public health 132

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) emergency and the state of emergency, subject to certain conditions.  This act is effective immediately and expires upon the rescission of the Governor’s Executive Order No. 103. New Mexico / Temporary Regulatory 03/17/2020  The New Mexico Financial Institutions Division is Regulation & Guidance regarding Work temporarily allowing mortgage licensees and staff to work Licensing from Home due to COVID- from their home residence, even if unlicensed, subject to Department / 19 Concerns certain requirements, including a prohibition against allowing Financial consumers to come into the home and certain security Institutions requirements. Division Agency homepage Brodsky04/07/20  “Businesses seeking clarity on essential or non-essential status may send inquiries to [email protected].” Restrictions on Money 04/09/20  Pursuant to the April 6, 2020 amended Public Health Services Businesses Emergency Order, further restricting nonessential businesses Pursuant to Department of and public gatherings, money services businesses are deemed Health Emergency Order a non-essential business “and must cease standalone Issued April 6, 2020 storefront operations immediately.” Operating via online or telephonic means is still permitted, provided that no in- person contact with customers is involved.  A limited exception exists for money services businesses physically located and operating within essential businesses (e.g., grocery or convenience stores). Essential Business Guidance 05/02/20  TheKider guidance responds to questions received by the Division for Small Loan Companies from small loan company licensees regarding non-essential re April 30, 2020 Public financial services businesses engaging in “curbside pickup Health Emergency Order and/or delivery services to customers” under the Public Health Emergency Orders related to the COVID-19 crisis.  The guidance clarifies that the Public Health Emergency Order’s “curbside pickup” provision applies only to “retail businesses,” which exclude financial services businesses. The guidance, therefore, concludesPC that “financial services providers not determined to be engaged in ‘essential 133

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) businesses’ are not permitted to provide financial services under the ‘curbside pickup’ provision of the current Public Health Emergency Order.” Updated Temporary 05/28/20 08/31/20  The guidance extends the temporary guidance issued on Regulatory Guidance March 17, 2020 authorizing all New Mexico mortgage Regarding Work from licensees “to work temporarily from their home residence, Home which may not be a licensed New Mexico Branch Location,” Due to COVID-19 Concerns subject to certain security requirements.  The guidance is now extended until August 31, 2020. New Mexico / Executive Order 2020-022 04/06/20 04/30/20  Executive Order 2020-022 renews and extends the statewide Office of Governor Brodsky public health emergency (declared in Executive Order 2020- Michelle Grisham 004). Executive Order 2020-036: 06/01/20 06/30/20  Executive Order 2020-036 renews the statewide public health Renewing the State of Public emergency, originally proclaimed in Executive Order 2020- Health Emergency 004, through June 30, 2020. New York / State NY Senate Bill 8243 6/17/20  SB 8243, effective immediately, requires New York regulated Legislature banking organizations and New York regulated mortgage servicers to “(a) make applications for forbearance of any payment due on a residential mortgage of a property located in New York widely available to any qualified mortgagor who, during the covered period, is in arrears or on a trial period plan, or who has applied for loss mitigation and demonstratesKider financial hardship during the covered period; and (b) grant such forbearance for a period of one hundred eighty days to any such qualified mortgagor who is in arrears or on a trial period plan, or who has applied for loss mitigation and demonstrates financial hardship, with the option to extend an additional one hundred eighty days.” o The covered period begins on (and forbearances may be backdated to) March 7, 2020. The covered period extends until the datePC on which there are no provisions, as imposed by various Executive Orders, 134

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) “that closed or otherwise restricted public or private businesses or places of public accommodation, or required postponement or cancellation of all non- essential gatherings of individuals of any size for any reason.”  Further, SB 8243 applies certain provisions to forbearances granted pursuant to Executive Order 202.9, which required the Superintendent of DFS to “ensure under reasonable and prudent circumstances that any licensed or regulated entities provide to any consumer in the State of New York an Brodsky opportunity for a forbearance of payments for a mortgage for any person or entity facing a financial hardship due to the COVID-19 pandemic.” Executive Order 202.9 is available here. o Provisions applicable to such forbearances include: for the term of the forbearance, (i) extending the term of the loan, (ii) waiving interest on principal, (iii) waiving late fees, (iv) giving mortgagors the option to have the arrears accumulated during the forbearance period payable, without being subject to penalties or late fees incurred as a result of the forbearance, either on a monthly basis or as a non-interest bearing balloon Kiderpayment; and (v) refraining from any negative reporting to any credit bureau regarding any of the foregoing options, as exercised by a mortgagor.  Note, SB 8243 does not apply to any federally-backed mortgage loans. New York / Office Executive Order No. 202.18 04/16/20  Executive Order No. 202.18, among other things, extends the of the Governor order suspending non-essential, in-person business operations to May 15, 2020. Executive Order 202.27: 05/05/20 06/04/20  Executive Order 202.27 expandsPC the declaration of a State Continuing Temporary disaster emergency (initially declared in Executive Order 135

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Suspension and Number 202, issued on March 7, 2020) for an additional 30 Modification of Laws days. Relating to the Disaster Emergency Executive Order No. 202.28: 05/07/20  Executive Order No 202.28, among other things, prohibits the Continuing Temporary “initiation of a proceeding or enforcement of either an Suspension and eviction of any residential or commercial tenant, for Modification of Laws nonpayment of rent or a foreclosure of any residential or Relating to the Disaster commercial mortgage, for nonpayment of such mortgage, Emergency owned or rented by someone that is eligible for Brodsky unemployment insurance or benefits under state or federal law or otherwise facing financial hardship due to the COVID- 19 pandemic for a period of sixty days beginning on June 20, 2020.” Executive Order No. 202.31: 05/14/20 05/28/20  Executive Order No. 2020.31, among other things, extends Continuing Temporary Executive Order No. 2020.28 through May 28, 2020. Suspension and Modification of Laws Relating to the Disaster Emergency Executive Order No. 202.33: 05/22/20 06/21/20  Executive Order No. 202.22 is “modified to permit any non- Continuing Temporary essential gathering of ten or fewer individuals, for any lawful Suspension and purposeKider or reason, provided that social distancing protocols Modification of Laws and cleaning and disinfection protocols required by the Relating to the Disaster Department of Health are adhered to.” Emergency Executive Order No. 202.34: 05/28/20  Executive Order No. 202.34, among other things, extends Continuing Temporary Executive Order No. 202.31 (see above) “until and unless later Suspension and amended or extended by a future Executive Order,” subject to Modification of Laws certain conditions. Relating to the Disaster PC Emergency 136

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order No. 202.35: 05/29/20  Executive Order No. 202.34, among other things, amends the Continuing Temporary conditions that Executive Order No. 202.34 (see above) placed Suspension and upon the extension of Executive Order No. 202.31 (see above), Modification of Laws consistent with Phase Two of New York’s reopening plan. Relating to the Disaster Emergency Executive Order No. 202.48: 07/06/20  Among other things, Executive Order No. 202.48 discontinues Continuing Temporary the suspension or modification of certain statutes, codes, and Suspension and regulations, causes such provisions to be in full force and Modification of effect again as of July 7, 2020. Among these resumed Laws Relating to the Brodsky provisions is: Disaster Emergency o “The directive contained in Executive Order 202.28, as extended, that prohibited initiation of a proceeding or enforcement of either an eviction of any residential or commercial tenant, for nonpayment of rent or a foreclosure of any residential or commercial mortgage, for nonpayment of such mortgage, is continued only insofar as it applies to a commercial tenant or commercial mortgagor, as it has been superseded by legislation for a residential tenant, and residential mortgagor, in Chapters 112, 126, and 127 of the Laws of 2020” (see above). Executive Order No. 202.70: 10/20/20 01/01/21  ExecutiveKider Order No. 2020.70, among other things, extends the Continuing Temporary prohibition (last extended, until October 20, 2020, by Suspension and Executive Order 2020.64) the initiation of a proceeding or Modification of Laws enforcement of an eviction of any commercial tenant for Relating to the Disaster nonpayment of rent or a foreclosure of any commercial Emergency mortgage for nonpayment of such mortgage.  Under Executive Order No. 2020.70, the prohibition is extended through January 1, 2021. Industry Letters 03/10/20  The New York DepartmentPC of Financial Services requires each regulated institution to submit within 30 days: (i) a response 137

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) New York / to the Department describing the institution’s plan to manage Department of the potential financial risk that could arise from the COVID- Financial Services 19 outbreak, including certain minimum assessments, (e.g., credit rating risks); and (ii) a response to the Department describing the institution’s plan to manage the risk of disruption to operations and services, including certain minimum components (e.g., preventative measures to mitigate operational disruption risks). NMLS State Agency 03/18/20  “Application processing continues. Please submit questions Operating Status as follows: spreadsheet Brodsky o Mortgage Loan Originator - [email protected] o Mortgage Banker - [email protected] o Mortgage Broker - [email protected] o Mortgage Loan Servicer - [email protected]” Emergency Regulation: New 03/24/20  The emergency regulation responds to Executive Order 202.9, Part 119 to 3 NYCRR: which was issued on March 21, 2020 and directed institutions Emergency Relief for New regulated by DFS to provide financial relief to consumers in Yorkers Who Can New York experiencing a financial hardship due to the Demonstrate Financial COVID-19 crisis. (Note, the emergency regulation does not Hardship as a Result of apply to any commercial mortgage.) COVID-19  For the duration of Executive Order 202.9, the emergency regulation requires regulated institutions to, subject to limited exceptions:Kider “(i) make applications for forbearance of any payment due on a residential mortgage of a property located in New York, widely available to any individual who resides in New York and who demonstrates financial hardship as a result of the COVID-19 pandemic; and (ii) subject to the safety and soundness requirements of the regulated institution, grant such forbearance for a period of ninety (90) days to any such individual.”  “As soon as reasonably practicable,PC and in no event not later than ten (10) business days following the promulgation of this 138

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) regulation, all regulated institutions shall e-mail, publish on their website, mass mail, or otherwise similarly broadly communicate to customers how to apply for COVID-19 relief and provide their contact information.”  Among other things, the emergency regulation also provides guidance to regulated institutions regarding the creation of qualifications to receive COVID-19 relief, processing applications for COVID-19 relief, and recordkeeping requirements.  “To the extent there are any inconsistencies between this Brodsky regulation and either of the two following Guidance Letters issued by the Department on March 19, 2020, this regulation shall prevail: (i) ‘Guidance to New York State Regulated and Exempt Mortgage Servicers Regarding Support for Borrowers Impacted by the Novel Coronavirus (COVID-19),’” and (ii) ‘Guidance to New York State Regulated Financial Institutions Regarding Support for Consumers and Businesses Impacted by the Novel Coronavirus (COVID-19).’” Update to the Guidance to 03/24/20 05/25/20  The guidance updates the March 10, 2020 industry letter New York State Regulated entitled “Guidance to New York State Regulated Institutions Institutions and Request for and Request for Assurance Relating to Potential Financial Assurance Relating to Risk Arising from the Outbreak of the Novel Coronavirus,” Potential Financial Risk whichKider imposed an April 9, 2020 deadline for responding to Arising from the Outbreak the industry letter. of the Novel Coronavirus  The update extends the response deadline to May 25, 2020. Update to the Guidance to 03/24/20 05/25/20  The guidance updates the March 10, 2020 industry letter New York State Regulated entitled “Guidance to New York State Regulated Institutions Institutions and Request for and Request for Assurance of Operational Preparedness Assurance of Operational Relating to the Outbreak of the Novel Coronavirus,” which Preparedness Relating to the imposed an April 9, 2020 deadline for responding to the Outbreak of the Novel industry letter. PC Coronavirus  The update extends the response deadline to May 25, 2020. 139

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition due to COVID- 19; and o the completion of the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later due to COVID-19. Industry Letter Re: 04/13/20  The NY DFS issued an Industry Letter identifying several Guidance to Department of areas of heightened cybersecurity risk as a result of the Financial Services (“DFS”) Brodsky COVID crisis and requesting that regulated entities assess Regulated Entities cybersecurity risks as described in the letter and address the Regarding Cybersecurity risks appropriately. It reminds regulated entities that Awareness During COVID- Cybersecurity Events should be reported to the NY DFS as 19 Pandemic promptly as possible and within 72 hours at the latest. Order Granting Temporary 06/12/20  The Order by the Superintendent of Financial Services grants Relief to COVID-19 Affected temporary relief to COVID-19 affected mortgage loan Regulated Servicers servicers concerning the requirement to provide periodic statements under 3 NYCRR 419.4(c). The Order extends this requirement for 60 days—i.e., from June 15, 2020 to August 14, 2020—for servicers unable to provide the periodic statements due to COVID-19. Kidero Any servicers able to provide the periodic statement by June 15, 2020 should do so. o Servicers utilizing the periodic statement extension must post a notice on their website stating that consumers will be entitled to receive the periodic statement on August 14, 2020 or shortly thereafter. Guidance to New York 06//17/20  DFS issued guidance to regulated financial institutions to State-Regulated Financial “urge” each financial institutions take specified “reasonable Institutions Regarding and prudent actions to supportPC consumers” incurring Support for New hardships as a result of the COVID-19 crisis. The specified 140

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) York Consumers Impacted actions are consistent with obligations under the CARES Act by the Novel Coronavirus of furnishers of credit report information and include, among (COVID-19) other things, taking steps to ensure compliance with the CARES Act (e.g., reviewing credit obligations that have been reported as delinquent), as well as promptly conducting a reasonable investigation (and promptly making corrections, if applicable) if a consumer disputes the accuracy of any consumer credit information provided to a credit reporting agency. New York / Guidance on CARES Act 04/17/20  The guidance responds to the CARES Act Recovery Rebate Attorney General Payments Brodsky payments and was issued “to make clear that emergency stimulus payments authorized by the CARES Act are exempt from garnishment under New York law, [and] any or debt collector that garnishes such payments has violated New York and federal law,” despite the CARES Act lacking an explicit exemption for such payments.  The guidance states that the NY Attorney General’s office “will aggressively prosecute such violations.” AG James Calls on 04/22/20  In letters sent to NY AG Letitia James called upon mortgage Mortgage Servicers to servicers to provide additional relief to all NY homeowners Provide Substantial COVID- adversely affected by the COVID-19 crisis in an effort to avoid 19 Relief for Homeowners a foreclosure crisis when the forbearance agreements end.  “TheKider OAG also intends to hold the servicing industry publicly accountable for meeting its obligations to homeowners during this crisis. We will be doing this by monitoring compliance with emergency laws and regulations, evaluating servicers’ performance at implementing 2 COVID-19 relief programs, and determining which servicers are working most effectively to protect the long-term financial health of New York’s homeowners and communities.”  The letters outlines a seriesPC of additional steps for NY mortgage servicers to take with regard to both immediate 141

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) relief (e.g., waived late fees, extended forbearance agreements, effective communication resources) and loss mitigation with long-term economic changes (e.g., extending mortgage terms, lowering interest rates, capitalizing arrears).  With regard to immediate relief measures, NY mortgage services must confirm with the NY AG within 10 business days of the letter that the outlined steps (or similar, alternative measures) have been implemented.  With regard to loss mitigation with long-term economic changes, NY mortgage services must confirm with the NY AG Brodsky within 30 business days of the letter that the outlined steps (or similar, alternative measures) have been implemented. North Carolina / Executive Order No. 121 03/27/20 04/26/20  The Directive orders, among other things, for individuals to Office of Governor stay at their place of residence, for non-essential businesses Roy Cooper and operations to cease, and for essential businesses and operations to, to the maximum extent possible, work from home or telework.  FAQs relating to the implementation of North Carolina’s Stay-at-Home Order are linked here. Executive Order No. 135 04/23/20 05/08/20  Executive Order No. 135, among other things, extends Executive Order No. 121.  North Carolina’s phased plan to reopen the economy is linked hereKider. Executive Order No. 141: 05/20/20 06/26/20  Executive Order No. 141 moves North Carolina into Phase 2 Easing Restrictions On (effective of easing COVID restrictions, replacing the Stay at Home Travel, Business Operations, 05/22/20) Order (Executive Order No. 138) with a Safer at Home And Mass Gatherings: recommendation. Phase 2  The Safer at Home recommendation includes, among other things, strongly urging telework to the greatest extent possible.  FAQs implementing ExecutivePC Order No. 141 are linked here.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) North Carolina / NMLS State Agency 03/16/20  Only essential North Carolina Commissioner of Banks Commissioner of Operating Status personnel are working. Banks (NCAOB) spreadsheet  “The Agency is closed to the public, except by appointment only. Most employees are telecommuting, but a skeletal crew reports to the office daily. The public and licensees are encouraged to use email rather than phone for a quicker response. For questions, please use the following email addresses: o Mortgage lender, broker or servicer – [email protected] Brodsky o Mortgage Loan Originators – [email protected] o Reverse Mortgage Companies – [email protected] o Money Transmitters – [email protected]” Operation Changes 03/17/20  Regulated entities should inform the OCOB of changes in operations or services offered.  The OCOB will be telecommuting as much as possible and request the use of electronic means for communicating. Agency homepage  The Commissioner continues to operate on a normal schedule. However, access to the agency’s office building will be by appointment only. NMLS COVID-19 Filing 04/02/20  The due date for completion of the following reports is Guidance extended by 30 days: Kidero the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later.  “A 30-day extension was granted to file the 1Q20 MCR and MSBCR and to submit annual financial statements. Also, the same extension was granted for uploading mortgage loan data through NCCOB Online.”PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  With regard to the completion of the 2019 Q4 MSB Call Report due to COVID-19, companies in need of additional time to complete this report should contact the North Carolina Commissioner of Banks with an extension request. Licensee Bulletin Board 04/02/20 06/14/20  “The North Carolina Office of the Commissioner of Banks is issuing a correction regarding timeline extensions for reporting. The MCR Q1 2020 and NCCOB Online Mortgage Data Upload reports are extended from May 15, 2020 to JUNE 14, 2020.”  “To provide flexibility with administrative burdens, the Brodsky NCCOB is extending the 2020 Q1 reporting deadlines for regulated mortgage entities that cannot meet the original deadlines for the following reports: o MCR Q1 2020 report is extended from May 15, 2020 to June 14, 2020 o MCR Standard Financial Condition and Financial Statement deadlines are extended from 90 days from the end of the company’s fiscal year to 120 days from the end of the company’s fiscal year o NCCOB Online Mortgage Data Upload is extended from May 15, 2020 to June 14, 2020”  “License items in the Nationwide Multistate Licensing System (NMLS)Kider will be updated to reflect these extensions. The NCCOB encourages licensees to meet the reporting deadlines whenever possible.” Licensee Bulletin Board: 09/17/20  The NCOB reiterated, on its Licensee Bulletin Board, that Exclusive Broker, Broker, “[a]lthough N.C. General Statute §§ 53-244.030(4) and (26) do Lender not allow a principal office or branch office to be located at an individual’s home or residence, they do not prohibit a mortgage loan originator from working remotely.” The post also reminds licensees thatPC “business records and files must be maintained at a principal office or licensed branch” and the 144

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) “licensee, and its employees, remain responsible for safeguarding all consumer information and ensuring effective oversight of business activities.” North Dakota / Executive Order 2020-06.4: 04/29/20  Executive Order 2020-06.4 authorizes the reopening of certain Office of the North Dakota Smart Restart (effective businesses, subject to specified conditions. Governor Protocols for Businesses 05/01/20) Resuming or Continuing Operations Executive Order 2020-06.7 05/22/20  Executive Order 2020-06.7, among other things (some of which are effective immediately), provides state employees Brodsky who have been teleworking since March 20, 20202 to either, beginning on June 1, 2020: (i) continue to telework or (ii) return to work at state facilities, subject to compliance with the ND Smart Restart protocols. North Dakota / Preparations for Covid-19 –  Financial institutions deeming it necessary to close or reduce Department of March 5 service hours at a branch location must notify the North Financial Dakota Department of Financial Institutions. Institutions- NMLS State Agency 03/23/20  There is limited Department staff onsite at the main office Consumer Operating Status with the majority of staff members working remotely. Division spreadsheet  Please send licensing emails to [email protected]. General inquiries can be sent to [email protected]. NMLS COVID-19 Filing 04/01/20  The due date for completion of the following reports is Guidance extendedKider by 30 days: o of the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Ohio / Division of Mortgage Loan Originators 03/23/20  MLOs may work from home, provided that the MLO is Financial and Installment Lenders reasonably overseen by a PCregistered or exempt company and Teleworking FAQ does not engage in activities that would classify their home 145

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Institutions, office as a branch of the company under the definition of a Consumer Finance “branch office” in the Ohio Revised Code 1322.01(G) (e.g., an MLO cannot use their home address location on business cards, post public signs or open hours, or otherwise publicly suggest that mortgage transactions are made at their home).  A Consumer Installment Loan Act licensee’s employees may make loans via the internet and telephone while working from home during the state of emergency, in addition to making loans in the parking lot of a licensed location.  With regard to remote work, “MLOs and other employees Brodsky must be reasonably supervised by the companies they work for, and the companies must have reasonable measures in place to ensure information security under applicable federal and state requirements.”  The Division will not enforce the regulation requiring RMLA registrants, during any state of emergency, to maintain 9am – 5pm office hours on the second Thursday of the specified months (February, April, June, August, October, and December).  “Financial and insurance institutions” are classified as “Essential Businesses and Operations.” NMLS COVID-19 Filing 04/01/20  The due date for completion of the following reports is Guidance extendedKider by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later.  “Ohio DFI will honor the NMLS time extension for required reports. Furthermore, OhioPC H.B. 197 gives companies a 90- day window after the current emergency period has ended, as 146

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) determined by the Ohio Governor, to file information necessary to maintain your license.” Ohio / Attorney Notice of Applicability of 04/13/20  The notice responds to the CARES Act Recovery Rebate General State Law Exemption payments and provides “notice to and financial to Payments Under the institutions that these payments are exempt from attachment, Federal Cares Act garnishment or execution under existing Ohio law,” despite the CARES Act lacking an explicit exemption for such payments.  “In the event of an execution against a CARES Act payment, the State of Ohio reserves the option of seeking intervention Brodsky to enforce the state law exemption. Some initial CARES Act payments may have arrived in accounts Friday. The State does not intend to intervene in the unlikely event that an execution was accomplished simultaneously.” Ohio / Department Director’s Order that 05/20/20  The Ohio Department of Health Director’s Order rescinds and of Health Rescinds and Modifies modifies certain sections of the April 30, 2020 Director of Portions of the Stay Safe Health Order: Ohio Order o The Order rescinds Section 3 (stay at home or place of residence) and Section 15 (Travel). o The Order modifies Section 5 (prohibited and permitted travel). Oklahoma / Office Governor Stitt Announces 04/22/20  Oklahoma announced a three-phase plan to reopen their state, of the Governor “Open Up and Recover (effective beginningKider on April 24, 2020. Safely” Plan 04/24/20)  A detailed description of each phase is linked here. Oklahoma / Interim Guidance Covid-19 03/13/20 04/30/20  MLOs and employees of regulated entities working from Department of home are allowed to work from a home that is not a licensed Consumer Credit location if: (a) the licensed MLO must be able to access its employer’s secure origination system directly from any out- of-office device the MLO uses through a VPN or similar system that requires passwords or other forms of authentication to access; (b)PC the licensed MLO does not keep any physical business records at any location other than the 147

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) licensed main office; (c) consumers do not physically visit the home; and (d) all security updates, patches, or other alterations to the devices’ security are maintained.  If a licensee elects to amend the address of a licensed location temporarily, no operations may occur at the compromised location until the Oklahoma Department of Consumer Credit is notified of the to the address of the original licensed location. During the period of operation at the temporary location, the original location must have a notice posted on the door at all times with the temporary location Brodsky address, contact information for the licensee, as well as the phone number of the Department. NMLS State Agency 04/03/20 04/30/20  All Oklahoma Department of Consumer Credit personnel are Operating Status (effective working remotely. spreadsheet 03/11/20)  “For COVID-19 questions, please email: [email protected], General Inquiries, please email: [email protected]. Please communicate electronically until further notice.” NMLS COVID-19 Filing 04/06/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; and o the MCR Standard Financial Condition.  “BasedKider on a recommendation from the NMLS Policy Committee, the Oklahoma Department of Consumer Credit will not take action if Call Reports and Annual Financial Statements are filed within 30 days of the placement of the License Item in NMLS. Please review the chart available on NMLS for the specific dates these items are due.” Amended Interim Guidance 04/23/20 05/31/20  The guidance amends the interim guidance issued on March Covid-19 13, 2020, which provided that MLOs and employees of regulated entities may workPC from a home even if the home not a licensed location, subject to certain conditions. 148

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The guidance, as originally issued, was effective through April 30, 2020.  The amended guidance extends the guidance through May 31, 2020. Second Amended Interim 06/01/20 07/05/20  The guidance amends the interim guidance issued on March Guidance – Temporary 13, 2020 (see above) and previously extended through May 31, Operations from Home and 2020 (see above), providing that MLOs and employees of Alternate Locations regulated entities may work from a home even if the home not a licensed location, subject to certain conditions.  The second amended guidance extends the guidance through Brodsky July 5, 2020. Third Amended Interim 06/30/20 09/30/20  The guidance amends the interim guidance issued on March Guidance – Temporary 13, 2020 (see above) and previously extended through July 5, Operations from Home and 2020 (see above), providing that MLOs and employees of Alternate Locations regulated entities may work from a home even if the home not a licensed location, subject to certain conditions.  The third amended guidance extends the guidance through September 30, 2020. Fourth Amended Interim 09/23/20 10/31/20  The guidance amends the interim guidance issued on March Guidance – Temporary 13, 2020 (see above), previously extended on three other Operations from Home and occasions (see above), providing that MLOs and other Alternate Locations employees of regulated entities may work from a home even ifKider the home not a licensed location, subject to certain conditions. The fourth amendment extends the guidance through October 31, 2020. Oklahoma / NMLS State Agency 04/17/20  All Oklahoma Department of Banking personnel are working Department of Operating Status remotely. Banking spreadsheet  “Licensees are encouraged to contact Angela Morris ([email protected]) or Jon Morphis ([email protected]) with any questions or concerns regarding any Oklahoma-PCspecific requirements.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS COVID-19 Filing 04/17/20  “Delays in filing annual financial statements are anticipated, Guidance and prior approval is not necessary. If possible, notify OK- DOB of the anticipated timeframe for submission of annual financials.” Oregon / State 2020 OR HB 4204 06/30/20 9/30/20  House Bill 4204 sets forth certain prohibited activities that apply to Legislature a lender of a financing agreement relating to property located in Oregon. The bill became effective on June 30, 2020, and applies to an “emergency period,” which runs from March 8, 2020 through September 30, 2020, unless extended by the Governor.  Among other things, lenders must provide written notice by mail to borrowers to inform borrowers of their rights for accommodation Brodsky under the bill. This notice must be provided by August 29, 2020— i.e., 60 days after the Bill’s effective date.  Note, although the bill does not grant express authority to the Oregon Division of Financial Regulation, the Division has provided a sample notice and guidance regarding its expectations for compliance with the requirements under the bill. Oregon / Division Temporarily Working from 03/13/20  Licensees must notify the Oregon Department of Financial of Financial Home Regulation of any MLO that is working form an unlicensed Regulation (DFR) location. In addition, licensees must provide copies of any temporary procedures put in place during this time and must ensure adequate supervision of MLOs.  The Division will allow MLOs and employees of licensed mortgage lenders, mortgage loan servicers, consumer finance companies,Kider payday/title lenders and manufactured structure dealers to work from home when the home is not licensed, if the licensed company meets certain requirements, including: (a) providing prior notice to the DFR of the intent to allow employees to work from home; (b) having appropriate policies and procedures, and providing such policies and procedures to the DFR, for remote work that cover, among other things, protecting consumer’s personal data, among other things, and (c) not allowingPC employees to meet consumer at the employee’s home. 150

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) COVID-19 Insurance and  The Division’s building is closed to the public, but the Financial Services Division remains available by phone and email. Information for Consumers NMLS State Agency 03/23/20  “Office is open to personnel but closed to the Operating Status public. Employees are encouraged to telecommute but are spreadsheet not required to do so. The public and licensees are encouraged to use email rather than phone for quicker response as the employee may be working from home without easy access to return calls.” NMLS COVID-19 Filing 03/31/20  “Oregon DFR is suspending our enforcement activity for an Guidance Brodsky indeterminate period of time. When the virus emergency is over, we will announce a specific deadline to comply with the deadlines that have passed. We will give at least 30 days for companies to get the reports filed. Companies who do not comply by the end of that period will be referred for enforcement action. “ Temporarily Working from Revised  The Department of Financial Regulation revised and Home 04/20/20 republished Bulletin 2020-6 to eliminate the April 30, 2020 expiration date of the Bulletin. The Bulletin is now effective until revoked. Grace Periods for Paying 07/31/20  Oregon DFR clarified that the required 60-day minimum Insurance Premiums grace period for property and casualty insurance requires that theKider policyholder “contact their property and casualty insurance company to request the one-time grace period to pay a past-due premium.” COVID-19 Insurance and Rev. 10/06/20  The Oregon DFR updated its COVID-19 home page for Financial Services Topics for consumers to clarify the expiration of its previously issued Consumers COVID-19 emergency orders: o “The Oregon Division of Financial Regulation issued a number of emergency orders and guidance about COVID-19 insurancePC and financial services issues. The

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) COVID-19 emergency orders that were issued during the COVID-19 pandemic expired in September.” Oregon / Office of Oregon Coronavirus Updated  The guidance was updated to clarify the following regarding the Governor Information & Resources 03/30/20 the March 23, 2020 Executive Order from Governor Kate Brown: “Executive Order 20-12 lists specific categories of businesses that must be closed. Other retail businesses not on that list may continue operating, but only if they can maintain social distancing protocols. Additionally, Executive Order 20- 12 does not apply to grocery stores, health care facilities, medical facilities, and pharmacies, but those facilities are Brodsky encouraged to comply with social distancing protocols whenever possible.” Executive Order 20-18: 04/17/20  The Executive Order responds to the CARES Act Recovery Protecting CARES Act Rebate payments and was issued to protect the payments Recovery Rebate Payments from most garnishments during the COVID-19 emergency from Garnishments, So period. Those Funds Can Be Used for Essential Needs Executive Order No. 20-24: 05/01/20 07/06/20  Executive Order No. 20-24 extends the COVID-19 declaration Extending COVID-19 state of emergency in Executive Order No. 20-03. of emergency from 20-03  The declaration of emergency is extended through July 6, 2020. Governor Kate Brown 05/07/20  GovernorKider Kate Brown announced further details of Phase I of Releases Plan for Rebuilding the plan for reopening Oregon, beginning on May 15, 2020 for a Safe and Strong Oregon eligible counties. Executive Order No. 20-25: 05/14/20  Executive Order No. 20-25 establishes a three-phase plan to A Safe and Strong Oregon: reopen Oregon. Maintaining Essential Health Directives in Response to COVID-19, and Implementing a Phased PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Approach for Reopening Oregon's Economy

Executive Order No. 20-27: 06/05/20  Executive Order 20-27, rescinding and replacing Executive A Safe And Strong Oregon Order 20-25 (see above), establishes statewide requirements (Phase II): and a phased reopening process for Phase I and Phase II of Maintaining Essential Oregon’s reopening plan. Health Directives In  The Executive Order includes, among other things, workplace Response To Covid-19, and restrictions during the “Baseline Phase,” including, for Continuing to Implement a example, the requirement for businesses to “facilitate Phased Approach for Brodsky telework and work-at-home by employees, to the maximum Reopening Oregon's extent possible” and the prohibition of in-office work Economy “whenever telework and work-at-home options are available, in light of position duties, availability of teleworking equipment, and network adequacy.”  The Executive Order allows for a limited return to office work in Phase II but still recommends remote work to the extent practicable. Further, workplaces in which employees do return to work “must designate, or continue to designate, an employee or officer to establish, implement, and enforce physical distancing policies, consistent with any applicable OHA guidance.” Executive Order 20-37: 08/31/20 12/31/202  ExecutiveKider Order No. 20 -37 extends 2020 OR HB 4204 (see Extending House Bill 4204’s above), which, among other things, imposes a foreclosure Mortgage Foreclosure moratorium, until December 31, 2020. Moratorium Until December 31, 2020 Executive Order 20-59: 10/27/2020  Executive Order 20-59, among other things, extends Executive Fourth Extension of Order 20-03 (initially declaring a statewide state of Executive Order 20-03 and emergency) and the COVID-19 state of emergency for an Covid-19 State of additional 60 days – i.e., throughPC January 2, 2021. Emergency 153

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  As part of the Governor’s re-evaluation of each COVID-19 related order, Executive Order 20-59 continues, without modification, among other Executive Orders: o Executive Order 20-37 (see above), extending Oregon H.B. 4204’s mortgage foreclosure moratorium until December 31, 2020; and o Executive Order 20-56 (see above), imposing a temporary moratorium on residential evictions for nonpayment, through December 31, 2020. Pennsylvania / Information & Guidance for 03/06/20  The Pennsylvania Department of Banking and Securities has Department of Non-Depository Brodsky stated that it “will not take exception to licensees and Banking and registrants working from alternate site locations, whether Securities licensed or not, only while the Commonwealth of Pennsylvania is under a Proclamation of Disaster Emergency.”  “Any document that will be mailed to the Non-Depository Deputy or placed in the drop-box including to the Deputy Secretary, Licensing Division, Bureau of Examinations, or Compliance Division must also be sent electronically to the appropriate email address and if the mailing includes a paper check, a digital copy of the physical check must be included. Licensing: [email protected]; Examinations: [email protected];Kider Compliance: ra- [email protected].” COVID-19 Information and  “The physical locations for the Department of Banking and Guidance for Financial Securities are currently closed and the Department is Institutions and Consumers maintaining operations through electronic communication.” NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR StandardPC Financial Condition; o the 2019 Q4 MSB Call Report; 154

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o the 2020 Q1 MSB Call Report; and o the completion of the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Agency Non-Depository 04/02/20  The Department clarified that only “certain” non-depository Homepage licensees are permitted to continue physical operations, including: check casher companies, consumer discount companies, credit services loan brokers, money transmitters, mortgage brokers, mortgage discount companies, mortgage lenders, mortgage loan correspondents, mortgage loan originators, mortgage servicers, pawnbrokers, and sales Brodsky finance companies. Non-depository licensees who must shutdown their physical locations include: debt management services, debt settlements services, and installment sellers. Agency COVID-19 05/11/20  The Department’s statement that only “certain” non- Homepage depository licensees are permitted to continue physical operations, moved to the Department’s COVID-19 webpage, removed the clarification of which licensees are continue physical operations (text that was published on April 2, 2020, see above). Pennsylvania / 2020 PA SB 841 04/20/20  The legislation authorizes, among other things, remote State Legislature notarial acts, by means of certain communication technology (as prescribed by the legislation), for the duration of the COVIDKider-19 disaster emergency and 60 days thereafter. Pennsylvania / Temporary Remote 04/20/20  The guidance responds to 2020 PA SB 841 and temporarily Department of Notarization authorizes remote notarization for all Pennsylvania notaries State public.  This temporary authorization will expire 60 days after the expiration or termination of the Governor’s Proclamation of Disaster Emergency, issued on March 6, 2020. Second Revised Limited 04/28/20  The Department revised its guidance for real estate Guidance for Real Estate professionals, appraisers, PCnotaries, title companies, and home Professionals, Appraisers, inspectors. 155

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Notaries, Title Companies,  The guidance specifies the types of residential real estate and Home Inspectors transactions for which in-person activities are authorized and lists the provisions that must be followed by those authorized to conduct in-person activities.  “Regardless of location, any which may be executed remotely, including virtual or telework activities for desktop appraisals, is permissible, as is any appraisal, including ‘drive-by’ appraisal, that does not require entrance into a physical location.” Pennsylvania / Amendment to the Order of 04/20/20 05/08/20  The amendment extends the Governor’s stay-at-home order Office of the the Governor of the Brodsky until 12:01 a.m. on May 8, 2020. Governor Commonwealth of Pennsylvania for Individuals to Stay at Home Order of the Governor of the 05/07/20 07/10/20  Beginning on May 11, 2020, the following requirements are Commonwealth of stayed for 60 days: Pennsylvania o The requirement that “notice be provided to debtors for Staying the Notice for each and every foreclosure action that is initiated” Requirements for Certain under (i) Pennsylvania law, the Loan Interest and Actions Protection Law (Act 6) and (ii) Homeowners Related to the Dispossession Emergency Assistance Act (Act 91). of Property o The requirement that “notice be provided to tenants Kiderand/or lessees when a landlord or manufactured home community owner intends to evict the tenant and/or lessee for nonpayment of rent” under (i) the Landlord and Tenant Act of 1951 and (ii) the Manufactured Home Community Rights Act.  “All foreclosures requiring compliance with Act 6 and Act 91 cannot commence for 60 days until July 10, 2020. All foreclosure timelines must be computed with a start date of July 10, 2020, at which pointPC any previously delivered Act 6 and Act 91 notices will be deemed delivered and any 156

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) foreclosure process may commence. The foreclosure actions requiring Act 6 and 91 compliance may proceed from that point forward in the normal course of action.” o Note, Act 91 also “mandates that a mortgagor have a face-to-face meeting with a consumer credit counseling agency to attempt to resolve the delinquency or default by restructuring the loan payment schedule or otherwise and face-to-face meetings create a public health danger.”  “All eviction proceedings requiring compliance with the Brodsky Landlord and Tenant Act of 1951 and the Manufactured Home Community Rights Act cannot commence for 60 days until July 10, 2020. All eviction timelines must be computed with a start date of July 10, 2020, at which point any previously delivered Landlord and Tenant Act of 1951 and Manufactured Home Community Rights Act notices will be deemed delivered and any eviction proceedings may commence. The eviction proceedings requiring compliance with the Landlord and Tenant Act of 1951 and the Manufactured Home Community Rights Act may proceed from that point forward in the normal course of action.” Amendment to Order of the 05/07/20 06/04/20  Governor Tom Wolf extended the Order directing Governor of the “IndividualsKider to Stay at Home” (dated April 1, 2020) through Commonwealth of June 4, 2020. Pennsylvania for Individuals to Stay at Home Amendment to the Order of 05/19/20  Governor Tom Wolf amended the March 19, 2020, Order the Governor of the directing “The Closure of All Businesses that Are Not Life Commonwealth of Sustaining.” Pennsylvania Regarding the  The amendment, effective immediately, include the addition Closure of All Businesses of paragraph Section 1(D),PC which reads as follows: that Are Not Life Sustaining 157

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o “All businesses in the real estate industry, which includes real estate professionals, appraisers, notaries, title companies, settlement service providers, escrow officers, home inspectors, mortgage loan originators, processors, and underwriters, and other necessary office personnel including administrative and information technology staff necessary to maintain office operations, are authorized to commence in- person operations statewide beginning on May 19, 2020. Such businesses must adhere to the Brodsky Administration’s Guidance for Businesses in the Real Estate Industry Permitted to Operate During the COVID-19 Disaster Emergency to Ensure the Safety and Health of Employees and the Public, which is incorporated herein.”  The Guidance for Businesses in the Real Estate Industry Permitted to Operate During the COVID-19 Disaster Emergency to Ensure the Safety and Health of Employees and the Public is linked here. State of Pennsylvania 08/31/20 11/29/20  The Proclamation Amendment renews the Proclamation of (Second) Amendment to Disaster Emergency for 90 days. Proclamation of Disaster Emergency Kider Pennsylvania / Amendment to the Order of 04/20/20 05/08/20  The amendment extends the Secretary of Health’s stay-at- Department of the Secretary of the home order until 12:01 a.m. on May 8, 2020. Health Pennsylvania Department of Health to Stay at Home Puerto Rico / COVID-19 Guidance 03/17/20  “All deadlines for the filing or submission of answers to Bureau of complaints, requests for information, all types of financial Financial reports (including quarterly and/or monthly reports), license Institutions renewals, in addition to anyPC other deadline imposed by the

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) OCFI or by law, which becomes due between March 16, 2020 and April 14, 2020, will be extended to April 15, 2020.” o All documents filed to comply with such deadlines will be received electronically. If electronic filing is not possible, the document, the licensee should call the OCFI, on the date in which OCFI resumes regular operations, for further instructions.  Abandoned property claims due to be filed between March 16, 2020 and March 30, 2020 must be filed on the business day following the first day in which the OCFI resumes its normal Brodsky operations.  Between March 16 and the reopening date of the OCFI, all consultations and/or questions from the industry, employees or general public must be submitted via email to the Deputy Commissioner of Financial Institutions. NMLS State Agency 04/16/2020  Essential Bureau of Puerto Rico Financial Institutions Operating Status personnel are working remotely only. spreadsheet  “The office is closed. Essential employees are working remotely. For assistance must email [email protected], [email protected] or [email protected].” NMLS COVID-19 Filing 04/16/20  The due date for completion of the following reports is Guidance extendedKider by 30 days: o 2020 Q1 Mortgage Call Report; o MCR Standard Financial Condition; o 2019 Q4 MSB Call Report; o 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later.  With respect to the Mortgage Call Report, the MSB Call Report, and the annual FinancialPC Statement, the agency has

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) stated that it “will not take administrative action, nor impose fines for late filings.” Rhode Island / Executive Order 20-32: 05/08/20 05/23/20  Executive Order No. 20-32 repeals Executive Order 20-14 Office of the Lifting Stay at Home Order, (issued on March 28, 2020 and renewed by Executive Order Governor Leaving Certain Restrictions 20-23), imposing a stay-at-home order, subject to certain in Place, Limited Re- exceptions. openings with Stringent  The Executive Order, among other things, encourages remote Health Regulations work “to the greatest extent possible,” limits social gatherings to five people, and implements a limited phase I re-opening. Executive Order 20-59 - 07/31/20 09/02/20  Executive Order 20-59 extends certain prior Executive Orders, Fifty-fourth Supplemental Brodsky(effective including, among others, the March 9, 2020, Executive Order Emergency Declaration – 08/03/20 20-02, declaring a state of emergency. Executive Order 20-02 is Extension of Various now extended until September 2, 2020. Executive Orders Executive Order 20-91 – 11/02/20 12/03/20  Executive Order 20-91 extends certain prior Executive Orders, Eighty-Sixth Supplemental (effective including, among others, the March 9, 2020, Executive Order Emergency Declaration – 11/03/20) 20-02, declaring a state of emergency. Executive Order 20-91 is Extension of Various now extended until December 3, 2020. Executive Orders Rhode Island / Informal regulator guidance  The Rhode Island Department of Business Regulations is Department of working from home but does not anticipate any changes to Business the review process. Regulations Interim Regulatory 03/13/20 04/30/20  “TKiderhe Department will not take administrative or other Guidance – Temporarily punitive action against a licensed MLO or the sponsoring Working from Home licensed company if”: (a) the licensed MLO access its employer’s secure origination system directly from any out- of-office device the MLO uses through a VPN or similar system that requires passwords or other forms of authentication to access; (b) the licensed MLO does not keep any physical business records at any location other than the licensed main office; (c) consumersPC do not physically visit the

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) home; and (d) all security updates, patches, or other alterations to the devices’ security are maintained. NMLS State Agency 03/23/20  “The RI Department of Business Regulation is open for Operating Status business, however, we are only staffing our offices spreadsheet with a reduced number of employees. The public is not recommended to visit our office. All employees are performing job functions remotely and remain in contact with industry and consumers.” NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: Brodsky o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Interim Regulatory Rev. 04/28/20 06/30/20  The Department extended its Interim Regulatory Guidance, Guidance – Temporarily temporarily authorizing licensed mortgage loan originators to Working from Home - work from home, regardless of whether the home is a licensed Updated branch.  The initial expiration date for the guidance was April 30, 2020.  The guidance is now effective until June 30, 2020. Interim Regulatory Rev. 06/23/20 09/30/20  TheKider Department extended its Interim Regulatory Guidance, Guidance – Temporarily temporarily authorizing licensed mortgage loan originators to Working from Home - work from home, regardless of whether the home is a licensed Updated branch.  The guidance was previously extended (see above) to expire on June 30, 2020.  The guidance is now effective until September 30, 2020. Interim Regulatory Rev. 09/28/20 12/31/20  The Department extended its Interim Regulatory Guidance, Guidance – Temporarily temporarily authorizing licensedPC mortgage loan originators to

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Working from Home - work from home, regardless of whether the home is a licensed Updated branch.  The guidance was previously extended (see above) to expire on September 30, 2020.  The guidance is now effective until December 31, 2020. South Carolina / Executive Order No. 2020-44 07/11/20 07/26/20  Executive Order No. 2020-44 renews the State of Emergency Office of the in South Carolina and outlines the measures to be taken in Governor response.  The Executive Order remains in effective for 15 days. Executive Order No. 2020-67 08/24/20 11/8/20  Executive Order No. 2020-67 renews the State of Emergency Brodsky in South Carolina and outlines the measures to be taken in response.  The Executive Order remains in effective for 15 days. Executive Order No. 2020-70 11/8/20 11/30/20  Executive Order No. 2020-70 renews the State of Emergency in South Carolina and outlines the measures to be taken in response.  The Executive Order remains in effect for 15 days. South Carolina / Homepage  “The Consumer Finance Division (CFD) is significantly Consumer Finance decreasing the number of staff who will be in the office Division of the beginning Friday, March 20, 2020. Even though CFD staff Board of Financial will be limited, they will still provide critical business Institutions operations, including NMLS transition process and license requests.”Kider  Questions to CFD should be sent in via email. Interim Regulatory 03/13/20 04/30/20  “The Division will not take administrative or other punitive Guidance action against a licensed MLO or the sponsoring licensed company if the MLO conducts activities requiring licensure from home if:” (a) the licensed sponsoring company has temporary policies, procedures, and a plan for supervision in place while under the State of Emergency; (b) the licensed MLO access its employer’sPC secure origination system directly from any out-of-office device the MLO uses through a VPN or 162

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) similar system that requires passwords or other forms of authentication to access; (c) the licensed MLO does not keep any physical business records at any location other than the licensed main office; (d) consumers do not physically visit the home; and (e) all security updates, patches, or other alterations to the devices’ security are maintained. Interim Regulatory Rev. 04/28/20 05/31/20  The South Carolina Consumer Finance Division of the Board Guidance – UPDATED of Financial Institutions updated its Interim Regulatory Guidance (see above), temporarily authorizes MLOs to work from an unlicensed home. Brodsky The update extends the expiration of the guidance (set to expire on April 30, 2020) through May 31, 2020. Interim Regulatory Rev. 05/29/20 06/30/20  The South Carolina Consumer Finance Division of the Board Guidance – UPDATED of Financial Institutions updated its Interim Regulatory Guidance (see above), temporarily authorizes MLOs to work from an unlicensed home.  The update extends the expiration of the guidance (set to expire on April 30, 2020) through June 30, 2020. June Consumer Finance 06/2020  The June Consumer Finance Report addresses, among other Report things, MCR extensions and SAFE MLO Testing:  “The Division recognizes the disruption COVID-19 has likely had on preparing the 2020 Q1 MCR, which was originally due MayKider 15. A 60-day extension has been granted to submit the report, and the filing deadline has been deferred until July 15, 2020. Companies must submit at least their application and origination activity. If a mortgage lender/servicer submits a completed report by the July 15 deadline, the Division will not take punitive action against the licensee.”  The report announces Prometric’s June 1 effective date for resuming testing for all programs where test centers are open (see above). PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o “The test enrollment window has been extended 180 days, and NMLS is currently working to provide test candidates with the option to take the test via an online remote proctoring delivery channel, which is expected to become available in the coming weeks.” South Carolina / Department Operations Due 3/23/20  “Modified deadlines include: Mortgage Log Filing due June 1, Department of to COVID-19 2020 (not March 31, 2020)” Consumer Affairs NMLS COVID-19 Filing 03/28/20  The due date for completion of the following reports is Guidance extended by 60 days: o the 2020 Q1 Mortgage Call Report due to COVID-19; Brodsky o the MCR Standard Financial Condition due to COVID- 19; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019. Mortgage Broker Guidance 05/28/20 07/01/20  The guidance expresses the Department’s “intent to on Remote Work/Mortgage temporarily allow licensed mortgage loan originators to work Log Submission from home, whether located in the state of South Carolina or another state, even if the home is not a licensed branch,” subject to certain provisions being met. o The Department updated the guidance concerning remote work to be effective through July 1, 2020.  The guidance also extends the filing deadline for the submissionKider of 2019 mortgage logs by mortgage broker companies. The deadline is extended to June 1, 2020. Interim Guidance For 06/01/20  The guidance is addressed to person and entities engaging in Businesses activities governed by the South Carolina Consumer Protection Code (e.g., consumer credit transactions) and those subject to the Department’s oversight.  The guidance responds to requests for guidance “regarding the implementation of business activities during the COVID- 19 pandemic, including paymentPC or performance deferrals and modifications.” 164

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The guidance “strongly encourages” the following measures: o “Increasing communication with borrowers regarding COVID-19 and the recommended methods for borrowers to contact the lender, especially if the lender has altered operations due to COVID-19. o Offering modifications or workout strategies to borrowers to help ensure successful repayment, including deferred or partial payments, which would avoid delinquencies and negative credit reporting. o Waiving late charges during the disaster declaration. Brodsky o Waiving deferment charges or waiving additional finance charges resulting from a deferment. o Waiving nonsufficient funds fees for dishonored payments or unsuccessful ACH withdrawals. o Suspending charging off accounts. o Suspending repossessions of collateral and foreclosure of real property. (For certain FHA-insured mortgages, the Department of Housing and Urban Development has placed a moratorium on foreclosures).” Agency Homepage  “The Department of Consumer Affairs is working remotely for the safety of our employees and customers. You can still file a complaint and submit applications for licensing online. YouKider can also email general questions to [email protected] or leave a voicemail by calling (803) 734-0359.” Homepage  “The Department is currently working at a limited capacity onsite. You can file a complaint and submit applications for licensing online. Filings you do not wish to make, or that are not available, online should be submitted via mail for processing.”  The Department can be reachedPC by phone or email.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Mortgage Broker Guidance 7/30/20  The South Carolina Department of Consumer Affairs updated on Remote Work/Mortgage the expiration date of the Interim Guidance for Mortgage Log Submission Brokers (see above) expressing the Department’s “intent to temporarily allow licensed mortgage loan originators to work from home, whether located in the state of South Carolina or another state, even if the home is not a licensed branch,” subject to certain provisions being met. o The Department updated the guidance concerning remote work to be effective until rescinded. The Department will provide notice to affected businesses Brodsky 15 days before rescission. South Dakota / Executive Order 2020-20 04/28/20  Executive Order 2020-20 implements South Dakota’s “Back to Office of the Normal Plan” detailed in an attachment to the Executive Governor Order. Executive Order 2020-26: 05/26/20 12/30/20  Executive Order 2020-26 extends the declaration of a State of COVID-19: State of Emergency in all of South Dakota until December 30, 2020. Emergency Extension Executive Order 2020-230 07/06/20 12/30/20  Executive Order 2020-30 rescinds Executive Order 2020-26 (see above) and, among other things, re-issues its declaration of a State of Emergency in all of South Dakota until December 30, 2020. South Dakota / Informal regulator guidance  The South Dakota Division of Banking anticipates being able Division of toKider work remotely and continue operations, but also indicated Banking that processing times may be impacted. Interim Regulatory 03/12/20 06/05/20  The Division “will not take administrative or other punitive Guidance – Temporarily action against a licensed MLO or the sponsoring licensed Working From Home company if the MLO conducts activities requiring licensure from home if”: (a) the licensed MLO access its employer’s secure origination system directly from any out-of-office device the MLO uses through a VPN or similar system that requires passwords or otherPC forms of authentication to access; (b) the licensed MLO does not keep any physical business 166

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) records at any location other than the licensed main office; (c) consumers do not physically visit the home; and (d) all security updates, patches, or other alterations to the devices’ security are maintained. NMLS State Agency 03/16/20 05/01/20  “Telephone calls are answered as normal with phones Operating Status forwarded; email is preferred method of communication” spreadsheet NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report due to COVID-19; Brodsky o the MCR Standard Financial Condition due to COVID- 19; o the 2019 Q4 MSB Call Report due to COVID-19; o the 2020 Q1 MSB Call Report due to COVID-19; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later due to COVID-19 Interim Regulatory 06/01/20 12/31/20  The guidance extends the interim regulatory guidance, issued Guidance – Temporarily on March 12, 2020 (see above), regarding temporarily Working From Home authorizing MLOs to work from home. (UPDATED)  The interim regulatory guidance is now extended through December 31, 2020. South Dakota / NMLS State Agency 03/23/20  All South Dakota Department of Consumer Affairs personnel Department of Operating Status areKider working remotely. Consumer Affairs spreadsheet  The Department provides the following contact information: Lauren Aguilar, 803-734-4249. NMLS COVID-19 Filing 04/20/20  The due date for completion of the following reports is Guidance extended by 30 days: o 2020 Q1 Mortgage Call Report; o MCR Standard Financial Condition; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later.PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Tennessee / Interim Regulatory 3/23/20 Until  The guidance recognizes decisions made by licensees to Department of Guidance further temporarily modify work assignments to reduce Financial notice exposure/transmission of COVID-19, provided that Institutions consumers do not travel to an employee’s residence to conduct business.  The guidance includes best practices for employees working remotely: o “All computers and other devices that contain, or are used to access, confidential information should be encrypted and secure. Brodsky o Employees should be required to access the licensee’s or registrant’s secure data system remotely using a virtual private network (VPN) or similar system that requires passwords or other forms of authentication to access. o All security updates, patches, or other alterations to the individual’s access device should be maintained. o The employee should not keep any physical business records at the remote location. o Activity should be conducted in a private environment, rather than a public area.”  Questions and concerns should be directed to the Department viaKider telephone or email. NMLS COVID-19 Filing  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Tennessee / Office Executive Order No. 22 03/30/20 04/14/2020  This Executive Order, among other things, (i) urges all of the Governor (effective persons in Tennessee to stayPC at home, with exceptions for 03/31/20) “Essential Activity” and “Essential Services,” as defined in the 168

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Order, (ii) orders all non-Essential Service businesses/organizations to close, (iii) encourages Essential Activities and Essential Services to limit the frequency of such activities and services to the greatest extent possible, (iv) prohibits employers from requiring or allowing an employee to report to work if the employer knows the employee has tested positive for COVID-19, at least until the employee has satisfied the conditions for discontinuing home isolation under CDC guidelines. Executive Order 23 04/02/20  This Executive Order No. 23 amends Executive Order No. 22 Brodsky (dated March 30, 2020) “Safer at home” provision in the first paragraph. Whereas Executive Order No. 22 “urged” persons in Tennessee to stay home, Executive Order No. 23 replaces this language to state that “all persons in Tennessee are required to stay home,” with exceptions for persons engaged in Essential Activity or Essential Services, as defined in Executive Order No. 22. COVID-19 Bulletin #22 04/21/20  Governor Lee announced that phased re-openings, subject to certain restrictions, will the week of April 27: “Next week, 89 of Tennessee’s 95 counties will begin a phased reopening of the state’s economy as we work to bring industries like retail, restaurants, and close contact services to a safe and methodicalKider opening.” Executive Order No. 30 04/28/20 05/29/20  Executive Order No. 30 supersedes and repeals, among (effective others, Executive Orders No. 22 and 23. 04/29/20)  Among other things, the Executive Order encourages and permits the return to work of certain employees—e.g., not businesses/organizations performing close-contact personal services (e.g., barber shops, salons) and certain gathering venues (e.g., bars, night clubs). o The Executive OrderPC strongly encourages work remote or telework from home to the greatest extent possible. 169

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order No. 32: An  Executive Order No.32 amends Executive Order No. 15 by Order Amending Executive adding several new provisions, including, for example, the Order No. 15 and Taking following: Other Necessary Measures o Paragraph 20.6, entitled: “Free copies of business to Facilitate the Treatment entity filings available for those using them to seek and Containment of state or federal disaster relief.” Under this provision, COVID-19 effective through August 1, 2020, the TN Secretary of State is authorized to “provide copies of business entity filings without charge when the business entity filings are sought in connection with obtaining relief Brodsky from a federal or state disaster assistance program.” o Paragraph 31.1, entitled “Remote shareholder meetings.” This provision suspends the Tennessee statute (Section 48-17-109) requiring that “shareholders participating in a meeting conducted through special communications be able to simultaneously hear each other during the meeting,” provided that certain procedures are established. Executive Order No. 33: An 05/05/20  Executive Order No. 33 rescinds, subject to a limited Order Amending Executive (effective exception, the portion of Executive Order No. 30 (see above) Order No. 30 to Allow 05/06/20) that prohibited businesses or organizations performing close- Reopening of Close Contact contact personal services to remain closed. Personal Services Pursuant  TheKider Executive Order subjects the reopening of businesses to to New Safety Guidelines the Close Contact Business Guidelines issued by the Governor’s Economic Recovery Group, linked here. COVID-19 Bulletin #33 05/12/20  “Tennessee Governor Bill Lee signed Executive Order Nos. 36 and 37, extending the state of emergency declaration from May 18, 2020 to June 30, 2020, in order to extend certain provisions facilitating the State’s continued response to the COVID-19 pandemic.” PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order No. 36: An 05/12/20 06/30/20  Executive Order No. 36, among other things, suspends the Order Suspending (effective notarization requirements for bonds and certain legal Provisions of Certain 05/18/20) documents. Statutes and Rules and  “The relevant provisions of Tennessee Code Annotated, Titles Taking Other Necessary 4 and 12, any other provisions of law, and related rules are Measures in Order to hereby suspended to the extent necessary to, with respect to Facilitate the Treatment and construction and commercial surety bonds, suspend any Containment of COVID-19 notarization requirement and allow all government departments and officials to accept surety bonds and powers of attorney containing electronic signatures and electronic Brodsky corporate seals affixed thereto.” Executive Order No. 37: An 05/12/20 06/30/20  Executive Order No. 37, in part, suspends: Order Extending Until June (effective o to the extent necessary, any law “requiring a Signatory 30, 2020, Executive Order 05/18/20) to execute a Document in the physical presence of, or No. 26 Temporarily while physically appearing before, a notary public or Permitting Remote Witness(es), or requiring a Witness(es) to witness a Notarization and document in the physical presence of, or while Witnessing of Documents to physically appearing before, a notary public or Further Contain COVID-19 another Witness(es),” subject to certain condition.; o the Online Notary Public Act, “to the extent necessary to permit a notary public to remotely notarize a Document in accordance with this Order”; and Kidero Tennessee Code Annotated, Section 8-16-103 “to the extent necessary to delay the expiration of terms of office of notaries public and on line notaries public set to expire between March 12, 2020, and June 15, 2020. Such terms of office shall instead expire on June 30, 2020.” Executive Order No. 38 05/22/20 06/30/20  Executive Order No. 38 supersedes and repeals the following previous Executive Orders:PC No.30, 33, and 35.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The Executive Order expands the number of Tennesseans who may return to work safely and urges adherence to health and social distancing guidelines. Executive Order No. 50 06/29/20  Executive Order No. 50, in part, extends Executive Order No. An Order to Facilitate and 38 (see above) through August 29, 2020. Respond to Continuing Effects of COVID-19 by Extending Executive Order Nos. 36 & 38 (as Amended by Executive Order No. 49) Brodsky Executive No. 52 An Order 06/29/20 08/29/20  Executive Order No. 52 extends the authorization of “remote Extending Remote (effective notarization and remote witnessing of Documents to allow Notarization and 06/30/20) persons to engage in commerce and execute legal documents Witnessing of Documents to without the need for in-person contact that creates the risk of Further Contain COVID-19 exposure to or spread of COVID-19,” subject to certain requirements (e.g., each the signatory, notary public, and witnesses must all be physically located in Tennessee during the real-time audio and visual remote communication). Executive Order No. 61: An 08/28/20 09/30/20  Executive Order No. 61 restates Executive Order No. 52 (see Order Extending Remote above), which extended the remote notarization authorization, Notarization and and extends the authorization through September 30, 2020. Witnessing of Documents Kider Executive Order No. 64: An 09/29/20 10/30/20  Executive Order No. 64 restates Executive Order No. 52 (see Order Extending Remote above), which extended the remote notarization authorization, Notarization and and extends the authorization through October 30, 2020. Witnessing of Documents Executive Order No. 66: An 10/28/20 12/29/20  Executive Order No. 66 restates Executive Order No. 64 (see Order Extending Remote (effective above), extending the remote notarization authorization, and Notarization and 10/30/20) extends such authorization through December 29, 2020. Witnessing of Documents PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Texas Home Lending 04/01/20  The joint financial regulatory agencies (Department of Guidance: Banking, Department of Savings and Mortgage Lending, Coronavirus Emergency Office of Consumer Credit Commissioner, and Credit Union Measures Department) issued guidance for home equity lenders to consider emergency measures as a response to the COVID-19 emergency.  The guidance reiterates requirements, which do not contain disaster/emergency exceptions, that a must be “closed only at the office of the lender, an attorney at law, or a title company.” In light of this requirement, the guidance Brodsky recommends that lenders who are keeping their offices open and closing home equity loans at authorized locations should close loans while abiding by social-distancing recommendations. Examples include: o “Physical separation between the borrower and any employees (which may include physical barriers, partitions, or separate rooms).” o “Use of video or audio conference to communicate with the borrower and verify the borrower’s identity.” o “Use of electronic systems for the borrower to view documents, as well as electronic signatures (in accordance with Texas law and the federal E-Sign KiderAct). o “Use of an online notary (in accordance with Texas law).” o “Minimizing the use of paper documents, and limiting the handling of paper documents after execution.” o “Implementing enhanced sanitization protocol for areas occupied by the borrower (in accordance with recommendations of health authorities).”  The guidance also addressesPC additional advances on existing home equity lines of credit, existing home equity 173

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) loans, modifying existing home equity loans, and the relevant disaster exceptions applicable to the foregoing. Home Equity Lending Rev. 04/22/20  The joint financial regulatory agencies (Department of Guidance: Banking, Department of Savings and Mortgage Lending, Coronavirus Emergency Office of Consumer Credit Commissioner, and Credit Union Measures Department) revised and updated the guidance for home equity lenders to consider emergency measures as a response to the COVID-19 emergency.  The update clarifies that the ability for an existing home equity loan to be refinanced without regard to the one-year Brodsky seasoning requirement is limited to circumstances when the existing home equity loan is refinanced into another home equity loan.  The update also adds a word of caution to lenders that if the existing home equity loan is refinanced into a loan that is not another home equity loan or reverse mortgage, then the refinance will be “subject to the requirements of Section 50(f)(2)(A), which also imposes a one-year reasoning requirement but does not include a similar disaster exception.” Texas / RE: Mortgage Entity 3/20/20  The Texas Department of Savings and Mortgage Lending Department of Licensed Location temporarily suspended “requirements that a physical office Savings and Requirements and Branch beKider open to the public during posted normal business hours.” Mortgage Lending Licensing  “Licensed MLOs may work from home or another remote location, whether located in Texas or another state, even if the home or remote location is not a licensed branch.”  “Licensed mortgage entities must ensure the following if a licensed residential MLO or mortgage loan staff works remotely: strict security of information is maintained, all physical business records are kept at a licensed office, not at the mortgage loan originator’sPC home, a remote location or in

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) any unlicensed branch office, and that consumers are not allowed to go to the mortgage loan originator’s home.” State Savings Banks – 03/30/20  The Department temporarily suspended the requirement that Independent Audits a state chartered savings bank submit an independent audit no later than the 90th day after the date of its fiscal year ends. Agency Homepage 05/12/20  “Due to the COVID-19 pandemic, the Finance Commission Building is closed to the public. During this time, you may reach the Department by calling the toll free number or by email.” Texas / Office of Regulated Lender Advisory Rev. 03/25/20  The Texas Office of Consumer Credit Commissioner will not Consumer Credit Bulletin: Coronavirus Brodsky take administrative action against licensees that conduct Commissioner Emergency Measures regulated lending activity from unlicensed locations, if: (a) the (OCCC) licensee prepares a written plan or documentation describing what steps it is taking, as well as the locations where regulated lending is taking place; (b) a licensee’s employees access information in accordance with the licensee’s written information security program under the federal Safeguards Rule, 16 CFR pt. 314; (c) the licensee’s employees access secure electronic information from the company using a VPN or similar system that requires passwords or other forms of authentication; (d) the licensed MLO does not keep any physical business records at any location other than a licensed location;Kider and (e) all security updates, patches, or other alterations to the devices’ security are maintained. Regulated Lender Advisory Rev. 04/16/20 05/31/20  The Texas OCCC revised its Regulated Lender Advisory Bulletin: Coronavirus Bulletin: Coronavirus Emergency Measures (originally Emergency Measures published March 13, 2020 and previously revised on March 25, 2020).  The revisions add an extension for the May 1 annual report deadline for the prior calendar year’s loan activity.  “If a regulated lender filesPC its complete 2019 annual report with the OCCC by June 1, 2020, then the OCCC will not take 175

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) an enforcement action against the regulated lender for failing to file a timely 2019 report.”  “If a regulated tax lender anticipates that it cannot file its report by June 1, it should contact the OCCC by email at [email protected]. All annual reports must be submitted in accordance with the OCCC’s instructions. The OCCC encourages regulated lenders to file their reports as soon as they are able to do so.” Regulated Lender Advisory Rev. 05/15/20 06/30/20  The Texas OCC revised its Regulated Lender Advisory Bulletin: Coronavirus Bulletin: Coronavirus Emergency Measures (originally Emergency Measures Brodsky published March 13, 2020 and last revised on April 16, 2020).  Under the revised guidance, the guidance is now in effect through June 30, 2020 (previously set to expire on May 31, 2020).  In addition to extending the effectiveness of the guidance, the revisions also clarify that the guidance directed towards regulated lenders anticipating an inability to file the annual report by June 1 is not limited to a “a regulated tax lender” but, rather, is addressed to “a regulated lender.” Regulated Lender Advisory Rev. 06/12/20 07/31/20  The Texas OCC revised its Regulated Lender Advisory Bulletin: Coronavirus Bulletin: Coronavirus Emergency Measures, originally Emergency Measures published March 13, 2020 and last revised on May 15, 2020 (Kidersee above).  The guidance is now in effect through July 31, 2020 (previously set to expire on June 30, 2020). Regulated Lender Advisory Rev. 06/12/20 07/31/20  The Texas OCC revised its Regulated Lender Advisory Bulletin: Coronavirus Bulletin: Coronavirus Emergency Measures, originally Emergency Measures published March 13, 2020 and last revised on May 15, 2020 (see above).  The guidance is now in effect through July 31, 2020 (previously set to expire onPC June 30, 2020).

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Regulated Lender Advisory Rev. 08/20/20 09/30/20  The Texas OCC revised its Regulated Lender Advisory Bulletin: Coronavirus Bulletin: Coronavirus Emergency Measures, originally Emergency Measures published March 13, 2020 (see above).  The revisions extend the guidance, now in effect through September 30, 2020. Regulated Lender Advisory Rev. 09/15//20 10/31/20  The Texas OCC revised its Regulated Lender Advisory Bulletin: Coronavirus Bulletin: Coronavirus Emergency Measures, initially Emergency Measures published March 13, 2020 (see above).  The revisions extend the guidance, now in effect through October 31, 2020. Regulated Lender Advisory BrodskyRev. 10/27/20 11/30/20  The Texas OCC revised its Regulated Lender Advisory Bulletin: Coronavirus Bulletin: Coronavirus Emergency Measures, initially Emergency Measures published March 13, 2020 (see above).  The revisions extend the guidance, now in effect through November 30, 2020. Texas / Industry Notice 2020-05: 03/30/20  The guidance does not include any required action, only Department of Business Continuity recommended considerations for maintaining essential bank Banking Planning Considerations – business operations during the COVID-19 emergency. COVID-19 Texas / Office of Proclamation of the 04/12/20  The Governor’s proclamation renews the origination the Governor Governor of the State of proclamation declared on March 13, 2020, stating that Texas COVID-19 poses an imminent threat to all of Texas. Executive Order No. GA-16 04/17/20 04/30/20  ExecutiveKider Order No. GA -16 implements the first step in (effective Texas’s plan to reopen. Reopened services will include, 04/24/20) beginning on Friday April 24, 2020, “retail services that are not “essential services,” but that may be provided through pickup, delivery by mail, or delivery to the customer’s doorstep in strict compliance with the terms required by DSHS,” as well as “additional services as may be enumerated by future executive orders or proclamations by the governor.” Governor Abbott 04/27/20 05/30/20  Pursuant to a request fromPC the Office of the Attorney General, Temporarily Allows For the Governor temporarily suspended “section 121.006(c)(1) of 177

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Appearance Before Notary the Texas Civil Practice & Remedies Code to the extent Public Via Videoconference necessary to allow for appearance before a notary public, for For Real-Estate Instruments the purpose of acknowledging real-estate instruments, via videoconference,” subject to conditions that must apply whenever this suspension is invoked (e.g., the notary’s use of two-way audio-video communication technology, the notary’s verification of the signatory’s identification, certain attestations by both the notary and the signatory, record keeping requirements).  The temporary suspension is effective until the earlier of May Brodsky 30, 2020 or the termination of the disaster declaration. Executive Order GA26: 06/03/20  Executive Order GA26 orders, among other things that a Relating to the expanded business establishment reopening in Texas may not operate opening of Texas in with more than 50% of the total listed occupancy, unless the response to the COVID-19 business qualifies for one of the listed exceptions. disaster Utah / Department State Public Health Order 10/14/20  The State Public Health Order, made by Interim Executive of Health / 2020-17: Declaring a Director, Richard G. Saunders, declares, effective Executive Statewide Public Health immediately, a statewide public health emergency due to the Director’s Office Emergency COVID-19 pandemic. The Order is effective until otherwise modified, amended, rescinded, or superseded Utah / Department Statement RE: COVID -19 03/20/20  “There is not, nor has there been any prohibition for Utah of Commerce / Communication and mortgageKider loan originators working from home offices. The Division of Real Regulatory Guidance ability to share, transmit, and review documents remotely Estate exists now more than ever. We would require that any Utah mortgage loan originator that is not working at a licensed Utah branch be linked on the NMLS to the entity location. Also, the entity would need to make their remote employees aware that their home is not a licensed location and should not be treated as such. In Utah, Principal and Branch Lending Managers are required to PCmanage, supervise, and oversee the activities of the MLOs working for their mortgage entity and 178

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) branch offices. These PLMs and BLMs need to have in place the means and ability to adequately ensure the accuracy and correctness of the loans originated from their companies.” NMLS COVID-19 Filing 04/20/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; and o the MCR Standard Financial Condition. Agency Homepage 05/12/20  “Fingerprinting services at the Division are temporarily suspended. New Real Estate Licensees who are unable to be fingerprinted, are being issued "CONDITIONAL Brodsky LICENSES." Conditional licensees will have until September 30, 2020 to be fingerprinted or their licenses will be denied.” Agency Homepage: COVID-  “Due to the Coronavirus (COVID-19) concerns, Real Estate 19 Notices and Appraisal licensees whose licenses expire in July or August can now renew their licenses without being enrolled in the FBI RAP Back Fingerprint System, (if they have completed their required continuing education (CE)). If your license expires July or August, complete your CE requirements and you will be able to renew your license on- time without being fingerprinted.” o Note, the Utah DRE has revised this update to provide for licenses expired in July or August, which was Kiderpreviously limited to June and July. Utah / Department Communication to 3/12/20  The guidance allows for companies to temporarily reduce or of Financial Mortgage Companies suspend operations or reduce operating hours, without the Institutions approval of the Utah Department of Financial Institutions. In these instances, the company should (1) provide adequate notice to its customers and (2) send a notice via email to the Department’s Supervisor of Consumer Credit and Compliance. PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS State Agency 03/23/20  “Telephone calls are answered as normal; email is preferred Operating Status method of communication.” spreadsheet  “Questions related to MSBs should be directed to [email protected]. Questions related to Mortgage should be directed to [email protected].” NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; Brodsky o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Vermont / Office Addendum 14 To Executive 05/15/20 06/15/20  Addendum 14 extends the declaration of a state of emergency of the Governor Order 01-20: until June 15, 2020. Extension of State of  The Addendum also (i) amends the Stay Home / Stay Safe Emergency Declared March Executive Order with respect to guidance relating to travel, 13, 2020; Be Smart/Stay Safe (ii) addresses general public mask use, and (iii) addresses lodging. Vermont / State 2020 VT SB 333 05/14/20  Vermont Senate Bill No. 333 establishes a moratorium on Legislature ejectment and foreclosure actions during the COVID-19 emergency, without relieving tenants of the obligation to pay rentKider and without relieving borrowers under a residential loan agreement of the obligation to make timely payments pursuant to their respective agreement.  The Act, among other things, stays pending foreclosure and ejectment actions until the end of the emergency period and allows for new foreclosure and ejectment actions only under specified conditions. Vermont / Memorandum RE: 03/13/20  The Vermont Department of Financial Regulation will not Department of Mortgage Loan Originators take administrative actionPC against licensed MLOs or their – Temporarily Working sponsoring companies if the MLO conducts activities from 180

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Financial from Home or a Company home, if, among other things: (a) the activity being conducted Regulations Designated Location due to is required by the sponsoring licensed company; (b) the MLO “COVID-19” is working from home because of the COVID-19 pandemic; (c) the MLO maintains all necessary licenses to conduct activity in Vermont; (d) no Vermont licensable activity is conducted in person at the home location; and (e) the licensed MLO access its employer’s secure origination system directly from any out-of-office device the MLO uses through a VPN or similar system that requires passwords or other forms of authentication to access. Guidance on Financial Brodsky3/26/20  The guidance responds to the 3/24/20 executive order by the Institution Operations governor directing Vermonters to stay at home or in their Under Addendum 6 to place of residence, leaving only for essential reasons Executive Order 01-20  “Vermont financial institutions should avoid all person-to- person contact in the delivery of services. As outlined in Addendum 6, all financial services shall be conducted remotely, to the maximum extent possible, by: o Mail o Automated teller machines and remote service units o Drive-through services employing appropriate precautions to avoid viral transmission o Online Kidero Telephone, or o Some other means that avoids in-person contact”.  “In order to promote remote transactions, financial institutions are encouraged to waive out-of-network ATM fees and any other fees or surcharges that would tend to discourage their use.”  “If a transaction or service cannot be done remotely, financial institutions should postpone the transaction or service until the end of the Stay Home PC/ Stay Safe period if possible.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS COVID-19 Filing 03/31/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the completion of the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later due to COVID-19. Memorandum: SBA 04/09/20  The guidance is issued to answer questions regarding the SBA Paycheck Protection Brodsky Paycheck Protection Program’s (PPP) relationship to Program Loans Vermont’s statutory lending limits for banks and credit unions.  The guidance concludes that Vermont’s statutory lending limits provide an exemption encompassing PPP loans, and, therefore, the Department “will not criticize banks or credit unions that make PPP loans.” Virginia / Office of Executive Order Sixty-One 05/08/20 06/10/20  Executive Order No. 61 and Order of Public Health the Governor and Order of Public Health (effective Emergency No. 3 implements the first phase of easing certain Emergency Three Phase One 05/15/20) business restrictions. Easing of Certain Temporary Restrictions Due to Novel Coronavirus Kider (COVID-19) Virginia Forward 05/08/20  Virginia Governor Ralph S. Northam presented Phase One of the plan to reopen Virginia.  Details regarding Phase One guidelines are linked here. Executive Order Number 05/12/20 05/28/20  The Executive Order and Public Health Order grant the Sixty-Two and Order of (effective Northern Virginia Region’s request to delay Phase One of Public Health Emergency 05/15/20) Virginia’s reopening plan / remain in Phase Zero and, Four: Jurisdictions accordingly, extends certainPC measures consistent with Phase Temporarily Delayed from Zero for the region. 182

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Entering Phase One in o “Executive Order 61, issued on May 8, 2020, and Executive Order 61 and effective at 12:00 a.m., May 15, 2020, eased certain Permitted to Remain in restrictions imposed under Second Amended Phase Zero Northern Executive Order 53 and Executive Order 55 (both Virginia Region Orders are collectively referred to as Phase Zero). Executive Order 61 sets out the Commonwealth of Virginia’s path into Phase One. The easing of the Phase Zero restrictions was premised, in part, on the Commonwealth’s achievement of certain metrics in responding to the novel coronavirus (COVID-19). The Brodsky easing of those restrictions is meant to be a floor, and not a ceiling. As previously acknowledged, some regions may need to move into Phase One more slowly than the rest of the Commonwealth. Prior to issuing Executive Order 61, I advised that any locality unready to move into Phase One, upon my review and approval of their request to remain in Phase Zero, could do so.” o “On May 9, 2020, local officials from the Counties of Arlington, Fairfax, Loudoun, and Prince William, and the Cities of Alexandria, Fairfax, Falls Church, Manassas, Manassas Park, as well as the Towns of KiderDumfries, Herndon, Leesburg, and Vienna (Northern Virginia Region) requested to remain in Phase Zero.” Executive Order Number 06/02/20  The Executive Order and Public Health Order implement Sixty-Five (effective Phase Two of Virginia’s reopening plan, excluding for and 06/05/20) purposes of the Order, the City of Richmond and the Order of Public Health Northern Virginia region. Emergency Six: Phase Two Easing of Certain Temporary Restrictions PC Due to Novel Coronavirus 183

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Executive Order Amended 06/09/20  Executive Order Amended No. 65 implements Phase 2 of Number Sixty-Five (2020) (effective Virginia’s reopening plan. and Amended Order Of 06/05/20) Public Health Emergency Six: Phase Two Easing Of Certain Temporary Restrictions Due To Novel Coronavirus (Covid-19) Governor Northam 9/24/20  Governor Ralph Northam announced the expansion of the Announces Expansion of Rent and Mortgage Relief Program (RMRP), which first Rent and Mortgage Relief Brodsky launched at the end of June with $50 million in federal Program for Landlords Coronavirus Aid, Relief, and Economic Security (CARES) Act funding to assist households facing eviction or foreclosure due to COVID-19. Landlords can now apply to receive financial assistance for current and past-due rental payments dating back to April 1, 2020 on behalf of their tenants who qualify for RMRP. The new application is available in addition to the existing tenant-based application. Governor Northam 10/7/20  Governor Ralph Northam today announced he is directing Announces Additional $12 million in additional funding from the federal Funding for Rent and Coronavirus Aid, Relief, and Economic Security (CARES) Act Mortgage Relief to Virginia’s Rent and Mortgage Relief Program (RMRP), due toKider high demand for financial assistance.  The program assists households and landlords with rent and mortgage payments to avoid eviction or foreclosure due to COVID-19. Virginia / IN RE: Amendment of 08/7/20 09/07/20  The Virginia State Supreme Court issued an order granting Supreme Court Eighth Order Extending Governor Ralph Northam’s request for a temporary Declaration of Judicial statewide moratorium on eviction proceedings in Virginia, Emergency in Response to from August 10, 2020, through September 7, 2020, halting all COVID-19 Emergency eviction proceedings relatedPC to failure to pay rent.

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  Governor Northam’s letter to the Court, dated July 24, 2020, requesting the moratorium is available here. Virginia / State Order Regarding the State 3/19/20 5/15/20  The Virginia State Corporation Commission (SCC) instituted Corporation Corporation Commission's the following 3 operating procedures: Commission Revised Operating (Effective o “In lieu of submitting any business entity, fictitious Procedures During Covid- 3/20/20) name or Uniform Commercial Code document to the 19 Emergency Office of the Clerk in paper, persons should use electronic filing options. Submissions by mail or commercial mail equivalents (FedEx, etc.) will be accepted but, due to the emergency, may not be Brodsky processed for an indefinite period of time.” o “The Commission has suspended in-person access to the Clerk's Office” and is requiring the following: . “All pleadings should be submitted electronically to the extent authorized. Any person seeking to hand deliver and physically file or submit any pleading or other document required to be filed in a case pending before the Commission shall contact the Clerk's Office Document Control Center to arrange the delivery. . For all other business, the Commission is Kiderdirecting the use of electronic filing systems, email, or telephone, in that order, for best services. “Any person seeking to hand deliver and physically submit any other document or payment to the Commission, shall instead deliver such filing or submission to the designated drop box located at the Security Desk in the 1st Floor lobby of the Tyler Building”. PCTo the extent feasible, documents deposited in this drop box by 4:45 p.m. on any 185

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) given business day will be dated and deemed submitted on that day. Documents deposited after this time will be dated and deemed submitted on the next business day.” o “Electronic filings made in the Clerk's Office may exceed the 100-page limit otherwise prescribed.” SCC Makes Temporary 3/19/20  The guidance directs all business be handled through Changes to Normal electronic filing systems, email, or by telephone. Business Operations During  The SCC is making temporary changes to normal business COVID-19 Health operations regarding on-site office activity to protect Emergency Brodsky members of the public and SCC employees until the COVID- 19 epidemic subsides. o “The Clerk’s Office will not be open to the public for in-person visits but will continue to receive and process documents, pleadings, and filings. In-person visits to other regulatory sections of the Commission are suspended except by advance appointment. Currently scheduled hearings are subject to further order of the Commission. If filings or other deliveries must be made, drop-offs are permitted. The evolving health emergency has reduced on-site SCC staffing. Many employees are teleworking. The processing of Kiderdrop-off deliveries may be delayed.” Order Concerning 3/19/20 May 15,  The customary service of Commission Orders by means of Electronic Service of 2020 paper copies to persons listed on docket service lists in the Commission Orders Commission's Case Management System is suspended immediately. o Service of Orders must be accomplished via e-mail. SCC Homepage  “The SCC is directing all business with the Commission to be handled through electronic filing systems, email, or by telephone. The COVID-19PC epidemic has reduced on-site staffing. For public health concerns, in-person visits to SCC 186

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) offices are temporarily suspended. If you must make filings or other deliveries, drop offs are permitted. The processing of such may be delayed.” Informal regulator guidance 3/24/20  Virginia regulators are mostly working from home now. They have set up secure emails for submitting application materials outside of NMLS and will invoice change of control fees, so we do not need to submit information outside of NMLS. Regulators are available through their work phone numbers. NMLS COVID-19 Filing 04/03/20  The due date for completion of the following reports is Guidance extended by 30 days: Brodsky o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; and o the 2020 Q1 MSB Call Report;  “Money transmitter licensees must seek a waiver from the Commissioner of Financial Institutions for an extension of time to file the audited financial statement required by § 6.2- 1905 D of the Code of Virginia. Waiver requests may be routed through Edward Gresham ([email protected]).” NMLS State Agency 04/03/20 5/15/2020  Only essential personnel are working. Operating Status (effective  “The COVID-19 pandemic has reduced BFI's on-site staffing. spreadsheet 3/20/2020) WeKider strongly encourage all business with the Bureau to be handled through electronic filing systems, email, or by telephone. If you must make filings or other deliveries, drop offs are permitted; however, the processing of such may be delayed.” NMLS COVID-19 Filing 04/06/20  “The Virginia Bureau of Financial Institutions does not plan Guidance on initiating administrative action against mortgage broker or mortgage lender licensees if unaudited annual financial statements are filed withinPC 30 days of their due date.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Order Regarding the State 05/11/20  The Order extends previously issued orders modifying the Corporation Commission's Virginia State Corporation Commission’s operating and Revised Operating service of order procedures (issued on March 19, 2020; see Procedures During COVID- above). The procedural orders, initially in effect until May 15, 19 Emergency 2020, are now extended until the Commission terminates them. NMLS State Agency 05/18/20 07/31/20  The Virginia Bureau of Financial Institutions extended the Operating Status length of its current operating status (essential personnel spreadsheet only) from May 15, 2020 to July 31, 2020. BFI Policy Statement 06/01/20 07/01/20  The policy statement expresses the Bureau of Financial Regarding COVID-19 Brodsky Institution’s intent to account for “extraordinary extenuating circumstances” resulting from COVID-19 and “will attempt to accommodate, consistent with law and sound practices, efforts made by licensees to minimize service disruptions.” Still, the Bureau emphasizes “that data security, internal controls, and adherence to safe and sound lending practices must retain paramount importance in alternative work programs.” Virginia/ Emergency Temporary 7/15/20  Provides temporary standards for employers to implement Department of Standard – Infectious (effective new workplace safety measures, including, among other Labor and Disease Prevention approximately things: Industry 7/27/20, when o “Employers shall ensure that employees observe published in a Kiderphysical distancing while on the job and during paid newspaper of breaks on the employer’s property”; general o “Employees that interact with customers, the general circulation) public, contractors, and other persons, shall be provided with and immediately use supplies to clean and disinfectant surfaces contacted during the interaction where there is the potential for exposure to the SARS-CoV-2 virus by themselves or other employees”; and PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) o Additional measures for workplaces with higher risk of employees spreading COVID. Washington / Real Estate and Mortgage 03/27/20  “While real estate activities along with mortgage lending Office of the Guidance – Stay Home, Stay activities have been approved as essential activities under the Governor Healthy Proclamation (20- Proclamation, such activities shall only be permitted under 25) the following restrictions and limitations: a) In-person meetings with customers are prohibited except when necessary for a customer to view a property or sign necessary documents; b) No real estate open houses shall be permitted; c) Property viewings, inspections, appraisals, and final walk- Brodsky throughs shall be arranged by appointment and limited to no more than two people on site at any one time, exercising social distancing at all times; and d) Except for the limited exceptions authorized above, all new real estate listings shall be facilitated remotely.”  “It is permissible to engage in real estate sales, as appraisers, settlement agents and escrow officers, property inspectors, mortgage loan originators, processors, and underwriters, and other necessary office personnel including IT professionals, and back office staff necessary to maintain office operations, along with those government workers necessary to review real estate excise tax and record documents. All real estate andKider mortgage activities must meet social distancing and appropriate health and worker protection measures before proceeding.” Essential Business Guidance 3/27/20  Real estate activities and mortgage lending activities have - Real Estate and Mortgage been approved as essential activities under the Stay Home, Transactions Stay Healthy Proclamation, provided that such activities are limited in the following ways: all new real estate listings must be facilitated remotely, subject to two limited exceptions: (1) In-person meetings with customersPC are permissible but only when necessary for a customer to view a property or sign 189

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) necessary documents; and (2) Property viewings, inspections, appraisals, and final walk-throughs are only permissible only when scheduled by appointment and must be limited to a maximum of two people on site at a time (provided they are exercising social distancing at all times).  Real estate open houses are prohibited.  “It is permissible to engage in real estate sales, as appraisers, settlement agents and escrow officers, property inspectors, mortgage loan originators, processors, and underwriters, and other necessary office personnel including IT professionals, Brodsky and back office staff necessary to maintain office operations, along with those government workers necessary to review real estate excise tax and record documents. All real estate and mortgage activities must meet social distancing and appropriate health and worker protection measures before proceeding.” Memorandum: Phase 2 Real 05/19/20  The memorandum, issued by Governor Jay Inslee, authorizes Estate Requirements – the real estate activities to resume immediately, subject to Proclamation 20-25 certain requirements. Resumed in-person activities are limited up to three people at a time during Phase 2 of Washington’s reopening.  “For purposes of this memorandum ‘real estate activities’ includeKider sales, appraisals, settlement and escrow services, inspections, mortgage lending, necessary office services, and government workers necessary to review real estate excise tax and record documents.”  The Phase 2 Real Estate COVID-19 Requirements are linked here. Washington / Consumer Loan and 03/05/20 06/05/20  The Washington Department of Financial Institutions (DFI) Department of Mortgage Broker Practices will not take administrative or other punitive action against a Financial Acts Interim Regulatory licensed MLO or the sponsoringPC licensed company if: (a) the Institutions Guidance licensed MLO access its employer’s secure origination system 190

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) directly from any out-of-office device the MLO uses through a VPN or similar system that requires passwords or other forms of authentication to access; (b) the licensed MLO does not keep any physical business records at any location other than the licensed main office; (c) consumers do not physically visit the home; and (d) all security updates, patches, or other alterations to the devices’ security are maintained. NMLS State Agency 03/19/20  “Most DFI staff are teleworking in response to the COVID-19 Operating Status outbreak. You can still access services online or by calling our spreadsheet office at 1-877-746-4334.” Guidance to Regulated and Brodsky3/20/20  The guidance urges servicers to take reasonable and prudent Exempt Residential actions to support adversely impacted mortgagors with Mortgage Loan Servicers actions, including: “forbearing mortgage payments for 90 Regarding Support for days from their due dates; Refraining from reporting late Borrowers Impacted by payments to credit rating agencies for 90 days; offering COVID-19 mortgagors an additional 90-day grace period to complete trial loan modifications, and ensuring that late payments during the COVID-19 pandemic does not affect their ability to obtain permanent loan modifications; waiving late payment fees and any online payment fees for a period of 90 days; postponing foreclosures for 90 days; ensuring that mortgagors do not experience a disruption of service if the mortgage servicerKider closes its office, including making available other avenues for mortgagors to continue to manage their accounts and to make inquiries; and proactively reaching out to mortgagors via app announcements, text, email or otherwise to explain the above-listed assistance being offered to mortgagors.” Agency Homepage  “DFI’s Tumwater office will be closed to the public for a minimum of two weeks beginning Wednesday, March 25. Our agency, however, is continuingPC operations that can be accomplished through staff teleworking. Please call our main 191

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) number at 360-902-8700 or toll-free at 877-RING-DFI (746- 4334) to be connected with the appropriate division for assistance.” Agency Homepage 04/02/20 05/04/20  Although DFI previously announced that the DFI Tumwater offices would be closed until April 8, 2020, DFI has now announced that the “office will be closed to the public until at least May 4.” Washington DFI - Division 04/08/20  The FAQs (1) affirm that safety deposit box access is an of Credit Unions COVID-19 essential business function of a credit union and (2) reiterate Questions and Answers that the Governor’s March 24, 2020 Proclamation 20-27 Brodsky removes the Remote Electronic Notary delayed effective date on October 1, 202, (making SB 5641 effective immediately to assist with real estate loan signing and notary/signature guarantee services. Washington DFI - Division 04/16/20  The Department updated its COVID-19 FAQs addressed to of Credit Unions COVID-19 credit unions (originally published on April 8, 2020). The Questions and Answers update addresses whether “a conflict of interest exist if the Credit Union processes the PPP loans for businesses owned by members of the board of directors.” The FAQs advise that “[w]ith the NCUA’s recent rule change, directors now have the ability to have PPP loans through their credit union.”  The FAQs link to this interim final rule by the Small Business Administration.Kider DFI Director Charlie Clark’s 04/16/20  DFI Director Charlie Clark sent a letter to Washington state’s Letter to Congressional congressional delegation to recommend policies for Delegation mitigating the COVID-19 economic impact. The recommendations include, among other things, congressional authorization for “a dedicated credit facility for nonbank mortgage servicers to access for liquidity purposes.” Washington Part of Multi- 04/21/20  “Washington borrowers with commercially-owned Federal State Student Education Family Education ProgramPC Loans or privately held student Loan Servicer Initiative To loans who are struggling to make their payments due to the 192

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Provide Borrowers Financial COVID-19 pandemic may be eligible for expanded relief,” Relief During COVID-19 including, among other things, 90 days of forbearance, Pandemic waived late payment fees, no adverse credit reporting, 90 days of ceased debt collection lawsuits. FINRA and NASAA 04/29/20  The Department announced that the Financial Industry Accelerate Delivery of Regulatory Authority (FINRA) and North American Online Testing Service Securities Administrators Association (NASAA) “are working together with input from other regulators and the industry to accelerate the delivery of an online testing service that will be administered and remotely proctored by test delivery Brodsky provider, Prometric.”  The service, which is currently in a trial phase, “will allow candidates to use their personal or firm-provided, camera- equipped computer to take qualifications examinations. Prometric staff will proctor the examination through the camera and other online tools.”  The Department also reported that Prometric has announced an intention “to open select test centers in limited geographic locations as early as May 1,” available only to essential service programs (e.g., financial services), subject to social distancing requirements. Spring 2020 Newsletter 04/29/20  The DFI Spring Newsletter confirms that: Kidero the March 20, 2020 Guidance to Mortgage Services Regarding With Mortgage Borrowers is the most up- to-date guidance to mortgage servicer licensees. o the March 5, 2020 Interim Guidance to Allow Mortgage Loan Originators to Work From Home is the most up-to-date guidance to mortgage loan originator licensees. Agency Homepage - 05/04/20 06/01/20  The Washington Department of Financial Institutions UPDATED extended the closure of itsPC Tumwater office to the public until

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) June 1, in recognition of the Governor’s “Stay Home. Stay Healthy” directive. Extension of Interim 05/07/20 07/10/20  The Washington Department of Financial Institutions Regulatory Guidance to reissued and extended the interim regulatory guidance Allow Mortgage Loan temporarily authorizing MLOs to work from home. Originators to Work from  The interim guidance was originally issued on March 5, 2020 Home and was effective through June 5, 2020.  The interim guidance is now effective through July 10, 2020. Spring 2020 Newsletter 05/11/20  The DFI Spring Newsletter, among other things, provides an examinations unit COVID-19 update and a mortgage industry Brodsky update.  With respect to the examinations update, the newsletter reports the ceased on-site compliance examinations, which went into effect on March 11, 2020. o “The change to remote examinations is currently effective through May. The Department will reevaluate the procedure as necessary based on ongoing guidance from the Governor’s Office.” o “If your company is selected for an examination and you need additional time to comply with examination requirements or if there are circumstances keeping you from complying, please contact us so we can work Kiderto find a way to keep your company compliant and operating safely in Washington.”  With respect to the mortgage industry updates, the newsletter reiterates that the authorization for MLOs to temporarily work from home has been extended to July 10, 2020 (see above) and that the Q1 Mortgage Call Report filing deadline has been extended to June 14, 2020, consistent with the NMLS Policy Committee’s amended policy allowing a 30-day extension for the filing of certain reports.PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) NMLS COVID-19 Filing 05/12/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. Amended Guidance to 06/18/20 09/30/20  This amended guidance amends the initial guidance to WA Washington State Regulated regulated and exempt residential mortgage loan servicers and Exempt Residential Brodsky issued on March 20, 2020 (see above). The amendments, among Mortgage other things, remove the specification of a 90-day period from Loan Servicers Regarding the list of actions that DFI urges mortgage servicers to take Support for Consumers (e.g., instead of urging “forbearing mortgage payments for 90 Impacted by COVID-19 days from their due dates,” as DFI did in the initial guidance, the amended guidance simply urges “forbearing mortgage payments”). Extension of Interim 06/22/20 12/31/20  The Washington Department of Financial Institutions Regulatory Guidance to reissued and extended the interim regulatory guidance Allow Mortgage Loan temporarily authorizing MLOs to work from home. Originators to Work from  The interim guidance was last extended through July 10, 2020. Home  The interim guidance is now effective through December 31, 2020.Kider Furlough Dates 06/30/20  “In compliance with the Governor’s directive for all state agencies to furlough staff one day a week for four weeks starting no later than the week of June 28, DFI staff will be on furlough and the DFI office will be closed the following days: o Thursday, July 2 o Friday, July 10 o Friday, July 17 o Friday, July 24” PC

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  “On these dates, online services for consumers and licensees — such as verifying a license, filing a complaint, accessing financial education or foreclosure assistance information, accessing information on how to apply for a license and necessary forms, etc. — will still be available. However, staff will not be available to answer calls, respond to e-mail or process applications or complaints.”  DFI has stated that they intend to announce the monthly furlough and additional closure dates for August, September, October, and November by the end of July. Brodsky The above-referenced directive of the Governor, dated June 17, 2020, is available here. DFI Continues Remote 08/12/20  The Washington DFI published an update on the status of its Work Operations operations, reiterating that DFI’s physical building is closed, staff are subject to furlough days, and most of the consumer services staff are working remotely. DFI also provided reassurances of “timely assistance” to customers, stating that: o applications are processed with normal turnaround times; o complaints are investigated remotely; and o examinations are conducted off-site.  The update also informed readers of potential flexibility by theKider DFI: “If DFI requested information from you, be sure to communicate if you cannot respond timely. Staff is allowing more time to submit items, provided the applicant or licensee remains in contact.”  Note, the DFI also published a separate article with advice to licensees for successful remote, off-site examinations, linked here. Extension of Interim 10/26/20 03/31/21  The Washington DFI reissued and extended the interim Regulatory Guidance to regulatory guidance temporarilyPC authorizing MLOs to work Allow Mortgage Loan 196

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Originators to Work from from home. The interim guidance is now effective through Home March 31, 2021. Fall 2020 Mortgage Industry 11/12/20  The Fall 2020 edition of the Division of Consumer Services Update Newsletter (the “Update”) reiterated the DFI’s Interim Regulatory Guidance—Temporarily Working from Home (see above), “temporarily suspending the requirement for MLOs to be related to a Washington licensed branch location within a certain distance to the MLO’s residence,” conditioned on the individual working from their residence in a manner consistent with the interim guidance. Brodsky The update indicates, however, that after the expiration of the guidance (currently set to expire on March 31, 2021), “MLOs may be required to obtain or otherwise have a Washington licensed branch location.”  The Update also emphasizes that the interim guidance applies only to MLO residential locations and not commercial locations. West Virginia / Unveiling the Comeback 04/27/20  West Virginia Governor Jim Justice announced a 6-week plan Office of the Plan for reopening West Virginia. Governor  The Comeback Plan’s home page is linked here. The Comeback Plan – 04/28/20  West Virginia Governor Jim Justice released additional Additional Clarifications clarifications regarding the 6-week plan for reopening West Virginia,Kider including tentative dates for implementing each week’s phase of the plan.  The Comeback Plan’s home page is linked here. West Virginia / House Bill 4748 03/25/20  On March 25, 2020, Governor Justice signed House Bill 4748 State Legislature (effective (passed on March 7, 2020), which, among other things, 06/05/20) imposes maximum fees for notarial acts. 2020 V.A. H.B. 5115 (1st 11/09/20  House Bill 5115 grants: Special Session) o Homeowners a 30-day stay of foreclosure proceeding on any mortgage orPC the execution of, or sale under, any deed of trust during the state of emergency, 197

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) provided that: (i) the homeowner defaulted on a note secured by a one-family to four-family residential property located in Virginia, and (ii) the homeowner requests the stay and provides the lender written proof that he or she was affected by the state of emergency by the sooner of 90 days of the initial declaration of the state of emergency or 90 days following the end of the state of emergency; o Tenants a 60-day continuance of unlawful detainer actions related to the nonpayment of rent due during Brodsky the state of emergency. The 60-day continuance begins on the initial court date, provided that the tenant appears on that date and provides written proof that he or she was affected by the state of emergency; and o Landlords, who rent a residential dwelling located in Virginia and default, during the state of emergency, “on a note that is secured by such dwelling unit and is subject to a foreclosure proceeding on any mortgage or to the execution of or sale under any deed of trust,” a 30-day stay of such proceeding, provided that the landlord requests the stay and provides the lender written proof that he or she was affected by the state Kiderof emergency by the sooner of (i) 90 days of the initial declaration of the state of emergency or (ii) 90 days following the end of the state of emergency.  The Bill defines “written proof” as: “(i) a paystub showing reduced earnings for a pay period during the period of the Emergency in response to the COVID-19 pandemic, (ii) a copy of a furlough notification letter or essential employee status letter indicating the employee's status as nonessential due to the Emergency, or (iii) anyPC other documentation deemed appropriate by a court or lender.” 198

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective)  The Bill does not apply to homeowners and owners “subject to protection from foreclosure under the provisions of a federal, state, or local law, regulation, or action enacted in response to the COVID-19 pandemic or the Emergency.” West Virginia / Emergency Announcements  “The majority of our staff will continue to work remotely Division of webpage throughout this pandemic event. We are fully functional and Financial have implemented our pandemic plan.” Institutions Regulatory Communication 3/13/20 5/1/20  The guidance states the intent of the West Virginia Division of -- COVID 19 Guidance -- Financial Institution to allow employees of regulated entities Temporary Assignment to temporarily to work from home or some other remote Alternative Location Brodsky location approved by the financial institution, whether located in West Virginia or another state. Regulated financial institutions may permit employees to work at home or from a designated remote location, to the extent that the position allows, as long as privacy and security issues may be adequately addressed. The following requirements apply: “1) The company must retain records identifying the dates and location(s) where each licensed mortgage loan originator worked remotely during the effective period when it does not match the employment location. The records must be available for review at the next examination cycle or upon request by the Division of Financial Institutions. 2) The companyKider must have a current and approved policy for access to the company’s secure origination system directly by the MLO through a VPN (or similar secured access) from any device approved by the company for use by the MLO in their daily work. The company must be able to demonstrate upon request, that such access is restricted to strong authentication procedures and passwords. 3) The licensed company is responsible for assuring that security is maintained with updates, patches, or otherPC alterations to devices used to access the system. Records of such maintenance 199

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) schedule must also be available upon request by the Division of Financial Institutions. 4) MLOs and other employees may not, under any circumstances, relocate any physical business records nor reproduce into paper format any record that contains personal or private information at any location other than those approved as a licensed location by the Division of Financial Institutions. 5) MLOs and other employees may not arrange to meet with borrowers at any remote or home-based location that has not been approved as a licensed branch location.” NMLS COVID-19 Filing Brodsky04/01/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; and o the 2020 Q1 MSB Call Report.  “Annual financial statement must be provided through NMLS before September 30, 2020.” Emergency Announcements 04/17/20 06/15/20  The West Virginia Division of Financial Institutions posted an webpage emergency announcement, extending the expiration date of its notice to non-depository institutions regarding temporary assignments to alternative locations (see above). The guidance wasKider originally published on May 13, 2020 and effective through May 1, 2020. Pursuant to the recent update, the effective date of the notice is now extended through June 15, 2020. Emergency Announcements 05/19/20 08/01/20  The West Virginia Division of Financial Institutions posted an webpage emergency announcement, extending the expiration date of its notice to non-depository institutions regarding temporary assignments to alternative locations (see above). The guidance was published on May 13,PC 2020, initially effective through May 1, 2020, and previously extended through June 15, 2020. 200

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Pursuant to the most recent announcement, the effective date of the notice is now extended through August 1, 2020. Emergency Announcements 07/20/20 09/01/20  The West Virginia Division of Financial Institutions posted an webpage emergency announcement, extending the expiration date of its notice to non-depository institutions regarding temporary assignments to alternative locations (see above). The guidance was published on May 13, 2020, initially effective through May 1, 2020, and previously extended through August 1, 2020. Pursuant to the most recent announcement, the effective date of the notice is now extended through September 1, 2020. Emergency Announcements Brodsky08/24/20 10/01/20  The West Virginia Division of Financial Institutions posted an webpage emergency announcement, extending the expiration date of its notice to non-depository institutions regarding temporary assignments to alternative locations (see above). The guidance was published on May 13, 2020, and previously extended through September 1, 2020. Pursuant to the most recent announcement, the effective date of the notice is now extended through October 1, 2020. West Virginia / Judicial Emergency 04/03/20 05/01/20  The amended declaration of a judicial emergency suspends Supreme Court of Declared, Amended Order certain in-person proceedings and extends or tolls certain Appeals of West deadlines, as set forth in the order. Virginia Wisconsin / Office Executive Order #94: 11/10/20  ExecutiveKider Order #94 makes the following recommendations, of the Governor Relating to Actions Every among others: Wisconsinite Should Take to o “All individuals should stay home as much as possible Protect their and only make trips when necessary”; Family, Friends, and o Businesses are “strongly encouraged” to, among other Neighbors from COVID-19 things: . Facilitate remote work to the greatest extent possible, including: offering online or virtual services (e.g.,PC virtual client meetings) and

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) holding internal meetings virtually or via conference calls; . When remote work is not possible,  Mandate masks in the work space;  Limit the number of people in a physical location to those “strictly necessary” for business operations;  Avoid staff congregating in shared workspaces;  Comply with social distancing, Brodsky including, if necessary, rearranging workspaces; and  “to the extent possible, increase airflow in work areas and conduct in-person meetings outside or in large open spaces”  The Executive Order includes only recommendations and no orders. Wisconsin / Mortgage Banking: COVID- 03/13/20  The Wisconsin Department of Financial Institutions “will take Department of 19 Information & Resources a no-action position concerning a licensed mortgage loan Financial originator working from a location that is not a licensed or Institutions registered office or branch office effective immediately, upon complianceKider with all of the following criteria: 1. The mortgage banker, broker or registered entity sponsoring the mortgage loan originator must notify the Division by sending an email to [email protected]. No response will be issued to the email submission due to the no-action position. 2. The licensed mortgage banker, broker or registered entity sponsoring the mortgage loan originator must maintain a list of mortgage loan originators who elect to work from home where the home is not a licensedPC branch. The list should include the name of the licensed individual, address where 202

State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) the individual is working and dates during which the individual worked at that address. The list must be submitted to the Division upon request. 3. The mortgage banker, broker or registered entity shall enact appropriate data security measures and reasonable supervision of the acts of the mortgage loan originator. 4. Physical business records are not maintained at the unlicensed location. 5. Consumers may not be present at the unlicensed location.” Emergency Guidance on 03/18/20  The guidance notifies payday and licensed lenders that, Character and Fitness effective immediately, an increase in customary interest rates, Requirements for Payday Brodsky fees, or any costs of borrowing in response to the COVID-19 and Licensed Lenders emergency will be deemed an “essential failure” of the licensee’s character and fitness.  The guidance also states that the Department will suspend or revoke the license of any licensee willfully engaging in any “opportunistic and exploitative conduct.” NMLS State Agency 03/24/20  The majority of the Department’s staff is working remotely Operating Status and communicating via email. spreadsheet NMLS COVID-19 Filing 04/02/20  The due date for completion of the following reports is Guidance extended by 30 days: o the 2020 Q1 Mortgage Call Report; Kidero the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later.  “Please note that per WI statutes, a mortgage banker or mortgage broker has 6 months after their fiscal year end to provide their required annualPC financial statements.”

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State / Agency Source / Document Date Expiration Update (Published/ Date Weiner Effective) Wisconsin / Emergency Order #28 Safer 04/16/20 05/26/20  The Emergency Order extends the Wisconsin stay-at-home Department of at Home (effective order through May 26, 2020. Health Services 04/24/20)  The original stay-at-home order (Emergency Order #12) is linked here. Wyoming / NMLS COVID-19 Filing 04/02/20  The due date for completion of the following reports is Division of Guidance extended by 30 days: Banking o the 2020 Q1 Mortgage Call Report; o the MCR Standard Financial Condition; o the 2019 Q4 MSB Call Report; o the 2020 Q1 MSB Call Report; and Brodsky o the annual Financial Statement for fiscal years ending Dec. 31, 2019 or later. NMLS State Agency 04/02/20  All Wyoming Division of Banking personnel are working Operating Status (effective remotely. spreadsheet 03/19/20)

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