ALTA Best Practices

Pillar One: Licensing

It is the policy of Old Towne Title to comply with all the licensing laws and regulations in all states in which it operated. Old Towne Title has in place the following controls:

1. Every employee of Old Towne Title required to be licensed by such laws and regulations is properly licensed.

The following employees of Old Towne Title hold a title insurance license:

  • Jennifer Sacco Producer License – License Number 600564
  • Jennifer Sacco WV National Producer – License Number 8223211
  • Sandra Raynor Producer License – License Number 653957
  • West Virginia Old Towne Title Producer – License Number 100155226
  • West Virginia Attorney Suzan D. Herskowitz Bar – License Number 8661

2. Old Towne Title holds a valid appointment with the following underwriter: Commonwealth Land and Title Insurance Co.

3. Old Towne Title is a Real Estate Settlement Agent registered with the Virginia Bureau of Insurance and is compliant with all RESA regulations. Old Towne Title last RESA audit was conducted on October 15, 2014.

4. Old Towne Title maintains a written procedure to verify licensing and registration for the agency and its employees on a schedule basis due date.

Pillar Two: Escrow Account Controls

Old Towne Title considers safeguarding its customer funds to be of the utmost importance.

Old Towne Title has in place the following escrow controls:

  • Credit and background checks on all employees with access to customer funds are run on an annual basis and pre-employment.
  • Three-way reconciliation of all escrow accounts is conducted on a monthly basis.
  • The following fraud controls offered by SoftPro: Positive pay, automated clearing house blocks, international wire blocks are in place and in use for every transaction.
  • Escrow and Operating funds are never commingled and remain in segregated accounts.
  • All accounts are maintained in federally insured financial institutions.
  • Only authorized employees have access to Old Towne Title’s escrow accounts.
  • All checks and wire transfers require two signature or approvals.
  • Reconciliation of accounts is performed by persons without check and wire transfer authority and are reviewed by management every month.
  • Management conducts regular audits of employee’s escrow files.
  • All escrow account controls are audited by management annually.
  • Employees receive regular training in proper handling of escrow funds and escrow accounting.
  • Employees receive regular training on identification of fraud, especially mortgage fraud.
  • Management reviews training levels for all escrow employees on an annual basis.

Pillar Three: Information and Data Privacy

It is the policy of Old Towne Title to comply with all federal privacy and data security laws and regulations and such laws in all states in which it operates.

Old Towne Title maintains the following information and data security controls:

  • The office lobby is physically separated from employee’s office space. All customers/vendors are escorted through office space.
  • Old Towne Title has a written Data Security Policy under which employees are trained, audited and compliant.
  • Physical files are maintained in a secure location when not in use.
  • Server room us isolated and accessible to only authorized employees.
  • Employees are prohibited from removing company files or information by paper or portable memory device.
  • Old Towne Title has commercially acceptable network security barriers and monitors in place.
  • Old Towne Title has an established Business Continuity Plan which is reviewed and updated annually.
  • Employees undergo background and credit checks at hiring and routinely thereafter.
  • Documents are transmitted by secure methods.
  • All Non-Public Personal Information is retained in secure locations and disposal is in compliance with state and federal law.
  • Employees are regularly trained on the collection, maintenance and disposal of Non-public personal information.
  • Old Towne Title has a written privacy statement which is disseminated to customers.
  • Management audits compliance with privacy statement on a regular basis

Pillar Four: Settlement Polices and Procedures

It is the policy of Old Towne Title to conduct every settlement in compliance with the RESPA and all other federal and state laws. Every settlement is conducted in accordance with the instructions of lender, seller, buyer, borrower and title insurance underwriter.

Old Towne Title maintains the following settlement controls:

  • Final settlement statements reflect actual disbursements made on behalf of the parties.
  • All closing instructions are collected in writing and are reviewed prior to closing.
  • Settlements are conducted in accordance with lender instructions.
  • All documents are reviewed by settlement employees prior to closing.
  • All mortgage payoffs are received in writing directly from the lender. Payoff funds are sent securely as directed in payoff letter.
  • Home equity lines of credit are properly closed and release of record.
  • Title insurance commitment requirements are satisfied prior to closing to ensure issuance of a policy.
  • All disbursements from Old Towne Title’s escrow account are properly documents in account ledgers.
  • All escrow disbursements require two approvers.
  • Employees are trained on proper conduct of a settlement and disbursement of escrow funds.
  • Employees are trained on mortgage fraud awareness and prevention.
  • All title insurance rate calculations are made through the underwriters online rate calculator and a written record is maintained in the file.
  • All available rate discounts are provided to customers.
  • Management conducts periodic audit of premium to verify compliance with underwriter’s rate structure.
  • Overcharge of any fee is promptly refunded to customer.
  • Documents are submitted for recording within two business days of settlement.
  • All recording shipments are tracked and recording of documents verified.
  • Old Towne Title is a Real Estate Settlement Agent registered with the Virginia Bureau of Insurance and is compliant with all RESPA regulations.

Pillar Five: Title Production

It is the policy of Old Towne Title to produce, deliver and remit every title insurance policy in a manner that is compliant with the lender instructions and the agency’s contract with its title insurance underwriter.

Old Towne Title has established the following procedures with respect to title insurance policy production:

  • Old Towne Title has established a goal of delivering policies to its customers within thirty days of closing.
  • Policies are reported to agency’s underwriter no later than the end of the first full month after closing.
  • Title insurance orders are processed on the same day or next business day after receipt.
  • Title searches are conducted in accordance with underwriting guidelines established by the title insurance company
  • Employees are regular trained on the production of title insurance policies.
  • All underwriting of title insurance policies is conducted by a licensed title insurance agent.
  • Title and closing files are preserved in accordance with applicable state law and instruction of title insurance underwriter.
  • Files are destroyed in accordance with state and federal privacy law.
  • The agency maintains a register of all polices issued with identifying information.
  • Old Towne Title has been appointed an agent for Commonwealth Land Title Insurance Company
  • Old Towne Title responds promptly to customer and underwriter requests in the event of a claim.


Pillar Six: Errors & Omissions and Fidelity Coverage

  1. Professional liability or errors and omissions insurance
    • Old Towne Title maintains professional liability insurance in the amount of no less than $1,000,000.00. This  amount is appropriate given the company’s size and complexity and the nature and scope of its operations; the amount is not less than the amount agreed to in the company’s underwriting agreement(s).
    • The insurance carrier is nationally known and has appropriate Best ratings.
    • Coverages/Endorsements are reviewed annually and are added or subtracted to reflect current changes in the practices of the industry and to reflect new threats to our business as they arise such as cybercrime.
  2. Fidelity bond coverage (Protection for Agent against employee dishonestly)
    • Old Towne Title maintains a fidelity bond policy in an amount of not less than $125,000.00. The company reviews both State law and our Issuing Agency Contracts to verify that our coverage meets or exceeds their respective requirements. This coverage is carried even if State law or our issuing Agency Contract do not require it from time-to-time as conditions or laws change.
  3. Surety bond coverage – Real Estate Settlement Agent (RESA)
    • Old Towne Title is a RESA-registers Virginia Settlement Agent and has provided to the Bureau of Insurance with a $200,000 surety bond for protection of its customers as a condition to registration. Old Towne Title is compliant with all RESA regulations and is in good standing with the Bureau of Insurance.

Pillar Seven: Consumer Complaints

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