TITLE INDUSTRY BEST PRACTICES - SETTING THE STANDARD


 

Title Financial Corporation of Wyoming recognizes that lenders are under intense scrutiny by regulators for the acts of third-party service providers. As a title and escrow agent, we are a key, high profile, service provider for our lender clients. We produce title assurance and insurance products and provide settlement services that enable you to make loans. Additionally, we handle millions of dollars in loan funds and are given access to your customers’ non-public personal information. We also interface directly, on your behalf, with your customers and other serviceproviders. We take our role in the real estate transaction and our obligations to our clients seriously.

Title Financial Corporation of Wyoming and our Subsidiaries, Gillette Title Services, Jackson Hole Title and Escrow and Laramie County Abstract and Title are committed to exceeding guidelines for compliance and business practices as set by the American Land Title Association, our underwriters, our regulators and our business partners. We have dedicated resources to design and implement policies and procedures to ensure our compliance with your regulatory needs and to train our team. We are not only committed to adhering to the highest standards of business practices, but to also helping our lender clients meet the challenge of complying with existing and future regulatory requirements.

Our goal is for our clients to have confidence in us and peace of mind. To accomplish this, we have adopted policies and procedures designed to protect the integrity of each transaction. We have a dedicated legal and compliance team responsible for training and auditing to these standards.

What We Do - Our Best Practices

Maintain current license(s) to conduct the business of title insurance and settlement services, including but not limited to:

  • Compliance with Applicable Business Laws and Regulations
  • Applicable License Documentation Available for Review

Maintain audit procedures and internal controls for all escrow trust accounts, including but not limited to:

  • Underwriter and State Audit Certification
  • Positive Pay, Dual Controls and 3 Way Reconciliation
  • Centralized Reconciliation Process
  • Technology for Online Banking with Appropriate Internal Controls in Place
  • Electronic Verification of Reconciliation

Maintain a privacy and information security plan to protect personal information as required by local, state and federal law, including but not limited to:

  • Clean Desk Policy
  • Procedures in Place for Data/Information Breach
  • Network Security
  • Heightened Protection of Electronically Transmitted Non-Public Personal Information

Maintain standard real estate settlement procedures and policies to ensure compliance with Federal and State Consumer Financial Laws, as applicable, including but not limited to:

  • Internal, Underwriter and Trade Association Training Provided to all Staff at Regular Intervals
  • Certification and Tracking of Employee Education
  • Internal File and Quality Control Auditing Performed at Regular Intervals

Maintain procedures related to title policy production, delivery, reporting and premium remittance, including but not limited to:

  • Ensure Timely Recording of Documents
  • Accurate and Prompt Delivery of Final Title Policies 
  • Monthly Underwriter Remittance and Policy Reporting

Maintain appropriate professional liability insurance and fidelity coverage, including but not limited to:

  • Fidelity Bond and Surety Bond Coverage Policies
  • Retain a Segregated Loss Reserve
  • Error and Omissions Insurance

Maintain procedures for resolving customer complaints, including but not limited to:

  • A Central Location for Customers to Lodge a Complaint — CFPB@titlefc.com
  • Track Communications with Customers 
  • Track the Resolution of Complaints

Who to Contact 

If there is anything you believe our Company can do in addition to these Best Practices or if you have questions, we would like to hear from you. Please contact us at CFPB@titlefc.com.

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