On May 24, the Florida governor signed HB 1185 to, among other things, authorize mortgage loan originators to transact business from branch offices and remote locations provided certain conditions are met. Mandatory conditions include: (i) the licensee has written policies and procedures for supervising loan originators working remotely; (ii) the licensee maintains a comprehensive written information security plan to oversee access to company platforms and customer information; (iii) in-person customer interactions do not occur at the loan originator’s residence unless it is a licensed location; (iv) physical records are not stored at a remote location; (v) customer interactions comply with federal and state information security requirements; (vi) appropriate security measures are established for when a loan originator working remotely accesses a company’s secure systems or documents; (vii) the licensee has the ability “to remotely lock or erase company-related contents of any device or otherwise remotely limit all access to a company’s secure systems”; and (viii) the “registry’s record of a loan originator who works from a remote location designates the principal place of business as the loan originator’s registered location, or the loan originator has elected a licensed branch office as a registered location.” The Act is effective July 1.
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