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DIFS Identifies Title Companies, Inspectors, Appraisers, Surveyors, Registers of Deeds and Notaries as Critical Infrastructure Workers

By Noah C. Hagan posted 04-06-2020 13:39


On March 30, 2020, the Department of Insurance and Financial Services (DIFS) issued two bulletins interpreting Governor Whitmer’s “Stay Home, Stay Safe” Executive Order 2020-21.

Executive Order 2020-21 states that some workers in the financial services sector are considered critical infrastructure workers—those workers who may continue to perform in-person work. DIFS Bulletin 2020-11-BT/CF/CU provides guidance on the specific industries included within the term financial services as used in Executive Order 2020-21:

  • 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)
  • bond issuers
  • title companies, inspectors, appraisers, surveyors, registers of deeds, and notaries

However, real estate brokers and agents are not considered critical infrastructure workers. Services provided by those workers must be done remotely. The bulletin instructs certain real estate–adjacent professionals, like appraisers and notaries, to contact their regulators with specific questions.

Executive Order 2020-21 states that critical infrastructure workers include workers in the insurance industry “only to the extent that their work cannot be done by telephone or remotely.” DIFS Bulletin 2020-12-INS explains that this includes “insurance companies, health maintenance organizations, third party administrators, nonprofit dental care corporations, producers, adjusters, and any workers necessary to the continued operation of these entities.” The bulletin also emphasizes that insurers must continue to process and pay claims in a timely manner and must continue to make all required filings with DIFS.