Town n’ Country Title, LLC affirms that it is compliant with the title insurance industry’s Best Practices as set forth in the American Land Title Association’s (ALTA) Best Practices Framework (Version 2.5).
By adhering to these practices we, at Town n’ Country Title (TNCT), are demonstrating our commitment to protect both lenders and consumers in their transactions. Our goal is to strive to always improve upon what we do, and to earn the trust of those with whom we do business; following these Best Practices means that we can provide quality products and service to our customers.
We are backed by two of the nation’s largest and strongest underwriters. These underwriters, First American Title Insurance Company and Old Republic National Title Insurance Company, routinely perform in-depth audits to ensure that Town n’ Country Title maintains the highest standards of quality.
Should more information be needed regarding the Best Practices of Town n’ Country Title, please feel free to contact Town n’ Country Title’s Compliance Officer at firstname.lastname@example.org
Establish and maintain current license(s) as required to conduct the business of title insurance and settlement services.
Town n’ Country Title maintains procedures and controls related to maintaining current licenses as required to conduct the business of title insurance and settlement services in the States of Wisconsin and Minnesota.
- All TNCT employees who are performing the functions of an intermediary in Wisconsin and/or Minnesota are required by the company to be licensed and maintain an active license in the applicable state(s).
- Documentation of compliance with all licensing requirements is maintained by TNCT’s Human Resources Manager.
- All annual reports and fees, as required by the Wisconsin Department of Financial Institutions, are also tracked for compliance to ensure they are submitted on a yearly basis so that TNCT can maintain an “active” status with the Wisconsin Department of Financial Institutions.
Adopt and maintain appropriate written procedures and controls for Escrow Trust Accounts allowing for electronic verification of reconciliation.
NOTE: These procedures apply to all custodial or fiduciary accounts including closing and disbursement accounts, recording accounts, construction disbursing accounts, underwriter remittance/premium accounts, and other similar accounts.
Town n’ Country Title maintains controls relating to the safeguarding of client funds and to minimize the exposure to loss of client funds.
- Controls are in place to ensure that funds are held under a fiduciary capacity and are not commingled with TNCT’s operating funds or anyone’s personal accounts.
- Appropriate procedures, such as 3-way reconciliations, are utilized to provide accurate account balances.
- TNCT’s banking is conducted by authorized personnel.
- Controls are in place so that a person leaving TNCT is immediately deleted as signatory and authorized wire transfer individual.
- A cyber-insurance policy is maintained against the acts of those trying to unlawfully transfer funds via electronic methods.
- Escrow account training is given to appropriate employees on such topics as: the need to securely handle customer funds, proper banking and wiring procedures, and reconciliation procedures.
- A third party service is used for reconciling fiduciary accounts.
Adopt and maintain appropriate a written privacy and information security plan to protect Non-Public Personal Information, as required by local, state, and federal law.
In accordance with the Gramm-Leach-Bliley Act, Town n’ Country Title has established a formal privacy and information security program that is appropriate given the size, complexity, nature, and scope of TNCT’s activities, as it relates to the safeguarding document privacy and information for the protection of data and Non-Public Personal Information (NPI).
NOTE: Non-Public Personal Information is described as personally identifiable data, such as information provided by a customer on a form or application, information about a customer’s transactions, or any other information about a customer that is otherwise unavailable to the general public. NPI includes first name or first initial and last name coupled with any of the following: Social Security Number, driver’s license number, state-issued ID number, credit card number, debit card number, or other financial account numbers.
- TNCT’s written policies associated with the privacy and information security program are given to all employees and the employees must acknowledge in writing that they have read and understand such policies. Said policies address the issues of network security, the proper disposal of NPI, and clean desk policy.
- An annual assessment of the standards and requirements affiliated with our information security program is conducted.
- Town n’ Country Title maintains network security and the Network Administrator regularly tests the security of the network.
- Employees have ongoing training to help ensure compliance with these policies.
- Town n’ Country Title has a documented disaster management plan to ensure adequate back-up, recovery and business continuation procedures.
- Town n’ Country Title reviews the security measures of third party service providers before transmitting NPI data to them.
Adopt standard real estate settlement procedures and policies that help ensure compliance with Federal and State Consumer Financial Laws, as applicable to the settlement process.
Town n’ Country Title has established procedures and controls relating to document recordation and rate/pricing procedures to put TNCT in compliance with applicable contractual obligations and Federal and State Laws.
- Our company has established policies regarding the timely recording of documents within 2 business days of settlement and policies regarding the tracking of rejected documents. E-recording is used, when feasible.
- Town n’ Country Title’s policies and procedure ensure that the correct amount is being charged to customers in accordance with the title insurance underwriter’s promulgated rate manual.
- Training is given to all applicable employees to make sure that recording and pricing procedures are followed.
- Procedures are followed to ensure that TNCT obtains E/O insurance for third party signing professionals.
Adopt and maintain written procedures related to title policy production, delivery, reporting and premium remittance.
Town n’ Country Title maintains procedures and controls relating to title policy production, delivery, reporting and premium remittance as necessary to meet its legal and contractual obligations.
- TNCT has procedures to help ensure that policies are issued to customers (lender and/or purchaser) within 30 days of either the later of when the transaction is disbursed or all of the conditions as shown on the commitment have been met.
- Remittance premiums for policies and endorsements which are due the underwriter, are sent timely in accordance with TNCT’s contractual obligations.
- Training is given to all applicable employees to make sure that policy production and remitting procedures are followed. If the procedures and policies regarding policy issuance and reporting change, further training is provided to make all applicable employees are made aware of these changes.
Maintain appropriate professional liability insurance and fidelity coverage.
Town n’ Country Title maintains professional liability coverage so that TNCT has the financial capacity to cover its professional services obligations.
- TNCT carries professional liability insurance for errors and omissions in accordance with its contractual obligations to its underwriters.
- Although not contractually or statutorily required, TNCT maintains a business owner’s insurance policy as protection against the dishonest acts of employees.
BEST PRACTICE NO. 7
Adopt and maintain procedures for resolving consumer complaints to ensure that TNCT is addressing issues of poor service to the consumer and/or issues of non-compliance.
Town n’ Country Title has established procedures and controls relating to tracking and resolving consumer complaints.
NOTE: A consumer compliant is defined as any matter brought to the attention of TNCT which is the result of the insured consumer’s dissatisfaction with the services, charges, or commitments/policies of Town n’ Country Title, LLC.
- TNCT maintains policies and procedure for handling consumer complaints. Said policies and procedures include the intake process, documentation, and tracking of complaints.
- Consumer complaints are resolved in a timely manner based on the complexity of the complaint.