Can a 4-40 Customer Representative Work Remotely?

CFO Jimmy Patronis signed an Executive Order today that states the DFS will not enforce the provisions of 626.7352 and 626.7354(4) until May 8, 2020, unless the order is extended.

The order can be viewed here:

Kevin R. Milner, MBA, CIC, ITP
Insurance Program Director
Gold Coast Schools

As the fears of the Coronavirus (COVID-19) spread, Florida insurance businesses are creating contingency plans for their employees. One options is to allow agency employees to work remotely; such as working from home.

If you are a licensed and appointed insurance agent, that is not an issue. But what if you are a 4-40 Customer Representative? Unfortunately, the answer to this question is “no”.

Florida statute F.S. 626.015(6) defines a “customer representative” as an individual appointed by a general lines agent, or agency to assist that agent or agency, in transacting the business of insurance from the office of that agent or agency. F.S. 626.7352 further defines a “customer representative’s office” as a location where a customer representative shall be housed wholly and completely within the actual confines of the office of the agent or agency whom he or she represents. The statute also states that a customer representative shall not maintain any such office or furniture, books, records, equipment, or paraphernalia at any other address or location, nor shall he or she maintain or make use of any other quarters, space, or address, for the purpose of the conduct of such business. No customer representative may be employed from any location except where an agent licensed to write such lines spends their full time in charge of such location.

Therefore, a 4-40 customer representative working remote is considered, by Florida Statute, a non-licensed representative, thus should not have any interaction with any customers. A list of activities a non-licensed employee may perform can be found in Chapter 69B-222 of the Florida Administrative Code

Gold Coast Schools reached out to Jean Jeune (Education Manager, Florida Department of Financial Services, Bureau of Licensing: Education Section) and asked if restrictions for a licensed and appointed 4-40 customer representatives, working remotely, would be lifted during the Governor’s recent state of emergency declaration. His response was “customer representatives are not statutorily permitted to work remotely.  We are not able to waive this requirement.  Currently, a licensed personal lines or general lines could work remotely.”

As a way of assisting agencies deal with this licensing restriction, Gold Coast Schools offers a variety of courses to help prepare 4-40 customer representatives obtain either a 2-20 General Lines agent license or the 20-44 Personal Lines agent license. You may ask, what are the benefits of these licenses versus a 4-40 customer representative license? Let’s take a look.

  • As a licensed agent, employees can work remotely. As a state subject to unpredictable weathering events, having the ability for your employees to work remotely can be essential in maintaining business operations.
  • The DFS restriction of 4-40’s working outside of the office will no longer be an issue.
  • As a licensed insurance agent, non-resident reciprocity is available, thus allowing agents to sell and discuss insurance in additional states.

Gold Coast Schools offers multiple ways of earning these licenses. As an approved education provider of the Florida Department of Financial Services, we offer 2-20 General Lines agent, 20-44 Personal Lines agent, and a 2-20 General Lines Agent Conversion Course. All of our pre-licensing courses are blended thus reducing the amount of time you are spending in a physical classroom.

For more details for in regarding these and many of the other course offerings, please contact a Gold Coast Schools’ Career Counselor at (800) 732-9140 or check out our website at

Kevin R. Milner, MBA, CIC, ITP joined the insurance industry in 2001. Currently, he is the Insurance Program Director at Gold Coast Schools headquartered in Tamarac, FL. Kevin earned his MBA from Fairleigh Dickinson University (NJ), is a national designated insurance professional and an active member of the Society of Insurance Trainers & Educators (SITE).