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Are You Prepared to Comply with the ALTA Best Practices Guidelines by October 2015?

Office of the Comptroller of the Currency and Consumer Finance Protection Bureau Mandate:

On Oct. 30, 2013, the Office of the Comptroller of the Currency (the OCC) raised the bar for bank compliance in the context of the management of banks’ third-party relationships.  The OCC now expects “more comprehensive and rigorous oversight of relationships that involve “critical activities.” This term refers to significant bank functions (e.g., payments, clearing, settlements, and shared services. Banks are expected to conduct appropriate due diligence before entering into new third-party relationships (not relying merely on prior experience), including on-site visits, independent audits and periodic independent reviews when a third party is engaged in providing critical activities.

What does this mean?

Adherence to American Land Title (ALTA) “Best Practices” framework constitutes compliance with both the CFPB and OCC requirements.  Compliance with these guidelines is required by October 2015!  Settlement organizations will need to be certified by an independent third party organization.

How TQS can help:

Third Party Assessments and System Implementation Support Services

TQS staff consists of Certified Lead Auditors, Certified Title Agents, IT professionals, and Attorneys. The Management Staff have previous experience owning and operating large Title Settlement companies.  We have certified high profile Title companies in South West Florida.  Our Client’s systems have been vetted and approved by Bank of America, Wells Fargo and Trustmark.

Our Approach:

A TQS Lead Auditor will conduct a Third Party assessment to verify the implementation of the supplier’s ALTA Best Practices Management System.  Document audit results and provide a final audit report.  TQS will conduct a closing meeting with the supplier to review findings and recommendations.  TQS will work with your suppliers to recommend corrective actions needed to become complaint with the ALTA Best Practices. 

 

Our Proven Approach to ALTA Certification

Gap Analysis: 

  • Utilize ALTA Best Practices Framework Assessment Procedures
  • Review Company Practices/Procedures/Work Instructions
  • Identify Current Practices That Can Be Used To Comply
  • Review Operating System Capabilities
  • Recommend processes need to comply
  • Conclude with management presentation – (Provide a Roadmap for compliance)

Assessment
Procedure
Number
ALTA Best Practices Framework: Assessment Procedures Assessment Recap
 ALTA Best Practice 1: Establish and maintain       current License(s) as required to conduct the business of title insurance and settlement services. Overall Assessment Recap:  If any individual procedure marked with an asterisk FAILS, Best Practice 1 FAILS.
1.01* Confirm the active status of the Company and/or individual Licenses/registrations for each state in which the Company conducts business.  Validate compliance with ALTA Policy Forms Licensing Requirement.   Documentation reviewed may include actual licenses, Department of Insurance or appropriate state regulatory agency websites/screenshots, Bar Association status, corporate or business registrations with the state and other documentation as applicable to state/license. 

Sample Selection:

• 100% of all required licenses and corporate registrations in all states in which Company operates on assessment date.

• View Company’s active ALTA Policy Forms License or verify compliance on ALTA website.
PASS / FAIL

 System Development & Implementation Support Services:

  • Review Gap Analysis Recommendations and Action items
  • Conduct Kick-Off – Orientation Training/Familiarize Staff with ALTA Best Practices
  • Cross-Functional Teams and TQS Facilitator Develop Interdepartmental Procedures
  • Client and TQS Management Track Project Progress
  • Regular Project Reviews / Maintain Action Items

On-Site Certification Audit:

  • Conduct a Two Day On-Site Assessment
  • Interview staff and Office Management
  • Verify That All Action Items Identified in The Gap Analysis Have Been Addressed
  • Review and verify all records required by ALTA Best Practices
  • Complete the Certification Package

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Contact Information

Vincent Zottola
Chief Operating Officer
Phone: 412-968-9101

Addresses

TQS, Inc.
1382 Old Freeport Road
Suite 2B
Pittsburgh, PA 15238
TQS, Inc.
701 S. Seas Drive #102
Jupiter, FL 33477
Phone: 561-899-0090

 

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