Does the FTC Safeguards Rule really apply to a small brokerage?▼
Yes. Mortgage brokers are listed among the non-bank financial institutions the FTC regulates under the Safeguards Rule, 16 CFR Part 314. The rule requires a written information security program, a Qualified Individual, a risk assessment, MFA, encryption, vendor oversight, training and an incident response plan. Firms that maintain information on fewer than a set number of consumers are exempt from a few provisions, like the written risk assessment, but not the core program. The amended rule also requires notifying the FTC after certain security events. Your counsel can confirm which exemptions fit; we build the controls and documentation.
Who should be our Qualified Individual?▼
The rule lets you name an employee or someone at a service provider, as long as one person is clearly responsible for overseeing the program. In small brokerages it’s often the owner or operations manager, supported by an outside IT and security provider. If you designate someone at a provider, you still keep responsibility, need to name a senior member of your own staff to oversee them, and must require the provider to maintain a program that protects you. We can support whoever you choose with the risk assessment, evidence and the annual written report.
How do we stop borrowers from emailing us tax returns?▼
Give them something easier. Most LOS platforms include a borrower portal, and if yours doesn’t fit, we set up an encrypted file-request link branded to your brokerage. We add it to your application emails and loan officer signatures, and coach your team to send the link instead of replying to attachments. Then we set mailbox retention so older attachments get removed on a schedule your counsel approves. Borrowers usually prefer it, since uploading from a phone camera is faster than scanning and attaching.
What’s the best defense against closing wire fraud?▼
Stop it on both ends. On your side, MFA and forwarding-rule alerts make it harder for an attacker to sit inside a loan officer’s mailbox watching for closing dates. Impersonation filtering and DMARC reduce spoofed messages using your name. On the borrower side, warn them early and in writing that you’ll never send wiring instructions by email and that they should confirm any instructions with the title company at a number they look up themselves. Repeat it as closing approaches, when attackers are most active.
Our loan officers use their own phones. Is that allowed?▼
It can be, with controls. We use MDM with a work profile on personal Android phones and user enrollment on iPhones, so borrower data stays inside managed apps like Outlook, Teams and your LOS app. You can require a passcode and encryption and wipe only the work data if the officer leaves or loses the phone. Their personal photos and messages stay private. What we discourage is borrower documents in personal texting apps or personal email, because you can’t control or retrieve them.
What happens when a loan officer leaves for another shop?▼
We run an offboarding checklist the same day: disable their email and sign-in, revoke LOS, CRM and pricing engine access, remove them from the password vault, wipe work data from their devices, and transfer their mailbox and pipeline to a manager. We also flag any wholesale lender portals where they had personal logins, so you can ask the lender to deactivate them. You get a record showing when each account was closed, which matters if a borrower later asks who had their file.
Do you provide Mortgage Brokers IT Services in Houston and nearby areas?▼
Yes. LayerLogix is based in the Greater Houston area and delivers mortgage brokers IT services to businesses across Houston and the surrounding communities, including The Woodlands, Spring, Katy, Sugar Land, Conroe, Cypress, and Pearland. For most Houston-area clients we can be on-site the same day when something needs hands-on attention, and our help desk is available during business hours, with after-hours emergency support. Call 713-571-2390 to check coverage for your specific address.
What does Mortgage Brokers IT Services cost for a Houston business?▼
Pricing depends on your size and what you need, so we do not publish a one-size-fits-all number — but Houston businesses generally pay a flat, predictable monthly fee rather than surprise hourly bills. We start with a free, no-obligation assessment of your current setup, then give you a clear quote in plain English with no hidden costs. That way you know exactly what you are getting and what it costs before you commit.