Employers in Florida have asked what happens when a brand‑new 4-40 Customer Representative or other Insurance License candidate finishes the required course but does not yet have a Social Security number (SSN). This situation is common with newly arrived legal immigrants and workers in the process of securing federal documentation, so it is important to understand what the Florida Department of Financial Services (DFS) will and will not allow under current law.

The Question from a Florida Employer

A recent employer question summarizes the issue well: “I have a new employee who just completed the 4-40 course, but she does not have a Social Security number yet. How can she get her certificate of completion and move toward her 4-40 license?” The answer requires looking at both the education side (course completion) and the licensing side (DFS and Florida law).

Florida Law on SSNs for Insurance Licenses

When applying for a Florida insurance license, the DFS is required to collect a Social Security number from each applicant for an agent, customer representative, adjuster, service representative, managing general agent, or reinsurance intermediary license. Section 626.171 of the Florida Statutes specifies that the written application must include the applicant’s full name, age, Social Security number, and other key identifying information.

This requirement is not just an internal DFS policy; it stems from federal law requiring states to obtain SSNs for certain licenses as part of child support enforcement and identity verification. In practice, that means DFS cannot issue a 4-40 Resident Customer Representative license unless the applicant has an SSN on file that matches the rest of the application and background information.

Course Completion vs. State Licensing

Completing an approved 4-40 Customer Representative designation course and receiving a certificate of completion is a required step, but it is separate from the DFS issuing the actual license. An education provider like OnLine Training (OLT) can typically issue a course completion certificate as long as the student has completed all course requirements and identity standards set by the school, even if the student’s SSN is still pending.

The DFS, however, will only treat that certificate as one part of the licensing file, alongside the online application, fingerprinting, and background check. In other words, the course opens the door to licensing, but the SSN is one of the keys the state must have before it can legally issue the 4-40 license.

What About an ITIN Instead of an SSN?

Some candidates have an Individual Taxpayer Identification Number (ITIN) rather than an SSN, especially early in the immigration and work authorization process. An ITIN can sometimes be used to help a student register with an education provider or in limited tax‑related settings, but it does not replace the SSN requirement in Florida’s insurance licensing statutes.

DFS guidance and the statutory language focus specifically on the Social Security number, which is required in the license application itself rather than an ITIN. As a result, a candidate may be able to move forward on the education side with an ITIN, but DFS will not issue the 4-40 license until a valid SSN is available and entered correctly in the application and MyProfile record.

Practical Steps a New Hire Can Take

While waiting for an SSN, a newly hired 4-40 candidate can still take several productive steps. This can help shorten the time from SSN issuance to full licensure and make onboarding smoother for both the employer and the new employee.

  • Complete an approved 4-40 Customer Representative course or RCSR designation program, such as OLT’s 40‑hour 4-40 Registered Customer Representative designation course, and secure the course completion certificate.
  • Confirm that all eligibility criteria are met: at least 18 years of age, a Florida resident, and a United States citizen or legal alien who possesses valid work authorization.
  • Create and update a DFS MyProfile account once an SSN is issued so that application details, including contact information and background disclosures, are current and complete.
  • Schedule and complete fingerprinting with a DFS‑approved vendor as soon as the application allows, so the background check can be processed quickly once the SSN and license application are submitted.

Employer‑Friendly Answer You Can Reuse

Employers often need a simple, consistent way to explain this to new hires and HR staff, so the following language can be adapted for internal handbooks, emails, or FAQs.

Florida law requires the Department of Financial Services (DFS) to collect a Social Security number from every applicant for an insurance license, including the 4-40 Customer Representative license, as part of the license application under section 626.171, Florida Statutes.

Your employee can complete an approved 4-40 course and receive a certificate of completion while waiting for a Social Security number, but DFS will not issue the actual 4-40 license until a valid SSN and work authorization are on file.

Once the SSN is issued, the employee should log in to DFS MyProfile, submit or update the license application, complete fingerprinting with an approved vendor, and then wait for DFS to finish the background check and issue the license.

For case‑specific questions, employers and applicants can contact the Florida DFS Bureau of Licensing at AgentLicensing@MyFloridaCFO.com or 850‑413‑3137 for the most current guidance.

Key Florida Resources You Can Link To

For employers and students who want to read the exact language or walk through every step, the following official resources are especially helpful. Linking to them in onboarding materials not only clarifies the process but also shows staff that you are following Florida’s legal standards.

How OLT Helps New Florida 4-40 Candidates

OnLine Training (OLT) has prepared Florida insurance professionals since 1998 and offers the state‑approved 40‑hour 4-40 Registered Customer Representative designation course so students can meet the educational requirement quickly and entirely online. The course is designed for working adults, with flexible access, clear explanations, and support to ensure each student can complete the program and obtain the completion certificate efficiently.

After finishing the course and securing the SSN, students can move directly into the DFS application process, making the path from classroom to licensed 4-40 Customer Representative as smooth and predictable as possible for both the employer and the new hire.

Other licensing courses are available through OnLine Training: Enroll in an Insurance Pre-Licensing course