1. Licensing:

Establish and maintain current license(s) as required to conduct the business of title insurance and settlement services.

2. Escrow Accounting Procedures:

Adopt and maintain appropriate written procedures and controls for Escrow Trust Accounts allowing for electronic verification of reconciliation.

3. Privacy and Information Security:

Adopt and maintain a written privacy and information security program to protect Non-public Personal Information as required by local, state and federal law.

4. Settlement Procedures:

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.

5. Title Policy Production & Delivery:

Adopt and maintain written procedures related to title policy production, delivery, reporting and premium remittance.

6. Professional Liability Insurance Coverage:

Maintain appropriate professional
liability insurance and fidelity coverage.

7. Consumer Complaints:

Adopt and maintain written procedures for resolving consumer complaints.