This is the first episode in a series detailing ALTA’s Best Practices which were promulgated in response to the CFPB. Over the coming months, we will break down all seven Best Practices and attempt to provide information detailing what things need to be done in order to be in compliance with the new regulations promoted by the CFPB. Please know this. . .we are all in the same boat. With the exception of Best Practice #4 related to settlements, we in the Title Agency business have to comply with the same sets of rules that you all do as Closing Attorneys.
Best Practice #1 relates to licensing and requires the implementation of procedures to make sure that all licensing requirements are met on an annual basis and that licenses are properly displayed. The first tip is:
Maintain Licenses in a Central Location. In the case of Closing Attorneys that applies to the following:
Annual Privilege License
Equally important to maintaining the licenses is establishing written procedures that assign responsibility to certain person or persons so that the licenses are properly maintained. If you are audited by a Lender, they will want to see these written procedures.
Create list of Personnel with licenses and licenses which need to be renewal with renewal dates.
Maintain copies of all licenses and keep in a central location or display as is appropriate.
Develop written procedures for renewing all licenses with assigned responsibilities.