2.03k 2.03h 2.03i 2.06 22 Are checks for underwriter premium payments that are outstanding longer than sixty (60) days after issuance researched and resolved immediately? 2.03k 2.03h 2.03i 2.06 23 Are all other checks outstanding longer than ninety (90) days after issuance researched and resolved immediately? 2.03m 2.03h 2.03i 2.06 24 Are all reconciling items researched and resolved immediately after being identified? 2.03l 25 If the reconciliation reveals a shortage, does your Company have a control or procedure for funding the shortage within 5 days? 2.01 2.03l 26 Describe the process for tracking and monitoring the items addressed in Questions 17 through 25 above, or identify/attach any existing reports used to track and monitor those items. 2.03k 2.03h 2.03i 2.06 27 Are the outstanding checks from the previous reconciliation checked against the current bank statement to determine whether they were cleared or remain outstanding? 2.03j 2.03h 2.03i 2.06 28 Are the outstanding deposits from the previous month's reconciliation checked against the current bank statement to determine whether they were cleared or remain outstanding? 2.03c 29 Does management review the reconciliations within one day of their completion? 2.03o 30 Does management periodically review cancelled checks and disbursement journals for unusual items? 2.03d 31 Are copies of the reconciliation accessible electronically by the insurance agency’s contracted underwriter(s)? 2.01 32 Describe your Company’s reconciliation procedures, and/or attach a copy of the most recent reconciliation and supporting documentation, and identify the individuals responsible for each procedure. EMPLOYEE TRAINING Corresponding Assessment Procedure 11 Questions 2.02d 1 Is each employee that has access to your Escrow Trust Accounts given a copy of your Company's written policies and procedures on escrow trust accounting when they are hired? 2.02d 2 Is each employee that has access to your Escrow Trust Accounts given a copy of your Company's written policies and procedures on escrow trust accounting when the procedures are updated?
All data on the network is protected by XXXXXXXXXX anti-virus software that runs on servers and workstations, and is updated automatically with on-line downloads from the XXXXXXXXXX website / via updates received on CD. (Use as applicable). This includes alerts whenever a virus is detected. Any viral infection that is not immediately dealt with by XXXXXXXXXX is notified to the (Agency Owner). All user data is backed up to tape automatically on a basis, using an appropriately secure system for fast indexing and data restoration. A full server backup to tape takes place weekly. Daily and weekly backups are securely stored in a room remote from the server room and reused on a fortnightly basis. A half-termly archive tape is preserved, and for the next half-term is securely stored off site, in case of catastrophic system loss such as a fire. A separate business continuity plan is established.
TRAINING Corresponding Assessment Procedure 6 Questions 4.01 1 Does your Company provide a copy of the written recording and pricing policies to new employees? 4.01 2 Does your Company provide updates to the written recording and pricing policies to all employees? 4.01 3 Does your Company provide staff training on your written recording and pricing policies? 4.01 4 Please list training conducted in the past 12 months on worksheet 4-B. 4.01 5 Does the training address proper handling of documents for recording and calculation of recording and transfer fees? 4.01 6 Does the training address the proper determination of fees for your services? 5 TITLE CERTIFICATION AND OBTAINING TITLE POLICY Adopt and maintain written procedures related to submitting final title opinion, documents and premium to title insurer in order to obtain timely issuance of title insurance policies post-closing. Purpose Appropriate procedures for the delivery of final title opinions, documents and premiums to the title insurer ensures attorneys meet their legal and contractual obligations under the lender’s written closing instructions. What You Should Know One issue lenders funding and selling loans have is primarily with the timely delivery of title policies and completion of post-closing requirements. Lenders are becoming more aware of the importance of the final policies and are enlisting the aid of title insurance underwriters to follow up on missing title insurance policies. Attorneys who are consistent offenders may notice a decrease in business from that lender. to Consider and Discuss How close is your office to complying with the recommendation of delivering final opinions, documents and premium to title insurers in sufficient time for issuance of policies within 30 days post-closing? What needs to be addressed in the written procedures to
Reverse Positive Pay, ACH and international wire blocks, if available in Company’s marketplace, to protect against unauthorized transactions. Review bank documentation such as monthly account analysis statement or bank positive pay entitlement documentation. If NA, PASS Assessment Procedure Number ALTA Best Practices Framework: Assessment Procedures Assessment Recap ALTA Best Practice 3. Adopt and maintain a written privacy and information security plan to protect Non-public Personal Information as required by local, state and federal law. Overall Assessment Recap: If any individual procedure marked with an asterisk FAILS, Best Practice 3 FAILS. 3.01* Obtain the Company’s information security program/policy to protect its Non-public Personal Information and verify that the program/policy is reviewed and updated at least annually, as necessary. PASS / FAIL If no written procedures, Procedure 3.01 FAILS. 3.02* Select a sample of 25 employees who have access to Non-public Personal Information (or 100% if fewer than 25 employees). Obtain evidence that they were trained in the Company’s information security program/policy to protect Non-public Personal Information. PASS / FAIL If 20% or more of items tested FAIL, Procedure 3.02 FAILS