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Consumer Financial Protection Bureau Statement

To better meet the needs of our lender customers with regard to their obligations as set forth by the CFPB, Guardian Title & Guaranty Agency and its affiliates have adopted the American Land Title Associations Title Insurance and Settlement Company Best Practices¬Ě as it guide in having policies and procedures in place to meet obligations expected of their vendors. Those best practices are as follows:

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

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

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.

4.      Adopt standard real estate settlement procedures and policies that ensure compliance with Federal and State Consumer Financial Laws as applicable.

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

6.      Maintain professional liability insurance and fidelity (Surety Coverage required in Ohio) coverage.

7.      Adopt and maintain procedures for resolving consumer complaints.

In addition to the above, Guardian Title & Guaranty Agency and its affiliates maintain the following:

1.      A written document destruction policy.

2.      Password Protection procedures.

3.      Positive Pay services through its banking relationships.

4.      Proof of E & O coverage of company vendors.

5.      An assigned Compliance Risk Manager to review compliance every 6 months.

6.      Strict Background and Credit check procedures for escrow employees.

7.      A record of successfully passing underwriter audits each year.

8.      Employee training with regard to security and privacy of consumer information.

Copies of some or all of these policies may be distributed on a case by case basis as authorized by the Executive Management of the company.