Mortgage Professionals Should be Optimistic About the Future

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Feature are not utilizing positive pay, contact your banker and get it established before the end of the month. Physical Security Clean-desk policies and a written physical security program are easy to implement. Write up a checklist of the actions to be taken at the end of each business day, ensure that computer monitors are shielded and not viewable by others, and that screen savers automatically activate after a brief period of inactivity. Where are your closed settlement files stored? Hopefully they are all electronically scanned and stored in clouds. If those files are not, you must move them to bonded secure storage. Storage units and home attics or garages are not adequate. If settlement files are stored in your office, is the space locked and access limited? Is there controlled entry with a record of who entered and what files were removed and when were they returned? Do you have an inventory of the files being stored? Are your offices alarmed? Are keys controlled, and not easily duplicated? Are there electronic access controls? IT Security This is the toughest requirement. Getting started is relatively simple, but requires some rather stringent rules and changes. The following are simple and inexpensive: • Strong passwords. • Lock down firewalls. • Eliminate Wi-Fi usage in the office. • Removing USB ports and DVD drives. • Establish a dedicated stand-alone computer for online banking. • Restrict the ability to surf the net. • Keep cell phones and other portable devices off the network. • Subscribe to Real Estate Data Shield (my only product plug). Here's Why: • Your employees receive the required IT security training and training certificate. • IT assessment and validation is offered. • Tailored IT programs are available. This by no means a complete listing of all that must be done. From a compliance perspective, it represents a reasonable start. These actions (and the documentation of each such enhancement) can be accomplished within a matter of a few weeks, and hopefully will demonstrate a good-faith compliance effort that should enable your agency to continue to receive business referrals from your lender and realtor networks as you progress to reach full compliance. One caveat: This is a personal recommendation after having participated in the ALTA Best Practices and Future of the Title Industry panels, as well as on testimony before the National Association of Insurance Commissioners. Th e M Rep o RT | 23 and closing documents, as well as disburse their settlement funds se- curely. Just because your operation is small doesn't mean that your clients shouldn't feel as secure as they would with a large business. For those that are out front in achieving compliance certifica- tion, the future isn't as bleak as it might appear. The conventional wisdom has been that settle- ment and escrow agents had until August 2015 for compliance certification—the time at which RESPA–TILA goes into effect. But that's not necessarily the case. Many agencies have already received requests for compliance documentation. The response time allowed is brief—in some cases, only a few days—and cer- tainly no time is available to start the process and complete the required certification standards. There are many companies that already have been removed from approved settlement listings because they had done little or nothing. It is in any company's best interest to start the compli- ance process now and complete ALTA certification sooner rather than later. This does not mean that everything has to be com- pleted now. However, time is not exactly on your side. For example, Wells Fargo, the nation's largest lender, said in a March newsletter to settlement agents that it endorsed ALTA's Best Practices and affirmed that the bank values local title and settlement providers who deliver a high level of professionalism, service, and quality to the their customers. It went on to say that it supports consumers' choice of title and settlement services, as long as "that choice is one able to consistently meet all applicable requirements." But that same newsletter also warned settlement service providers that lender over- sight is increasing, so settlement agents should be in the process of documenting their compliance- enhancement efforts and must be prepared to demonstrate their Top Performer status. In other words, it was a clear sign that the compliance clock is ticking. Be ready to meet the new standards before the alarm sounds. RichaRd M. Reass Richard M. Reass is founder, president, and CEO of Reliant Title and Segin Software, LLC, which developed the RynohLive escrow account and financial management system. His companies are based in Virginia Beach, Virginia. "Frankly, title and settlement companies are only being required to do what agents should have been doing all along. Your clients should expect that your agency will protect their personal data and closing documents, as well as disburse their settlement funds securely."

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