Select a sample of days within the assessment period for the escrow funding/settlement/disbursement accounts and verify closing attorney is performing, at a minimum, a daily reconciliation of the receipts and disbursements. Select a minimum of 5 or 10% of all interest bearing PASS / FAIL / NA 2.04* escrow or trust accounts, whichever is greater, If 25% or more of items (maximum of 25). If total population is less than 5, tested FAIL, Procedure select 100%. Verify that the Company maintains 2.04 FAILS records/documentation supporting activity for interest bearing (customer investment) escrow accounts. If NA, PASS For ALL Escrow Trust Accounts, determine whether PASS / FAIL 2.05* the Escrow Trust Accounts are maintained at Federally Insured Financial Institutions unless directed by the beneficial owner. Sample Selection: PASS / FAIL / NA 2.06* If 20% or more of items Select a sample of 5 files or 100% of closed files, tested for any whichever is less, during the assessment period and FAIL perform the following: Procedure 2.06 FAILS. Compare the settlement statement and file ledger and investigate differences. Review closed file for supporting documentation for If NA, PASS disbursements over $1,000 listed on the settlement statement. Investigate any unsupported disbursements. Verify disbursement and receipt dates and amount on the file ledger with the bank statement or copies of cleared checks, to determine timely clearance. Verify funds were received/ deposited prior to disbursement. For outgoing wire transfers, verify compliance with Company’s policy for initiation and approval. For accounts reviewed in Assessment Procedure PASS / FAIL / NA 2.07* 2.03, verify that the Company utilizes Positive Pay or
Select a sample of days within the assessment period for the escrow funding/settlement/disbursement accounts and verify closing attorney is performing, at a minimum, a daily reconciliation of the receipts and disbursements. 2.04* Select a minimum of 5 or 10% of all interest bearing escrow or trust accounts, whichever is greater, (maximum of 25). If total population is less than 5, select 100%. Verify that the Company maintains records/documentation supporting activity for interest bearing (customer investment) escrow accounts. PASS / FAIL / NA If 25% or more of items tested FAIL, Procedure 2.04 FAILS If NA, PASS 2.05* For ALL Escrow Trust Accounts, determine whether the Escrow Trust Accounts are maintained at Federally Insured Financial Institutions unless directed by the beneficial owner. PASS / FAIL 2.06* Sample Selection: Select a sample of 5 files or 100% of closed files, whichever is less, during the assessment period and perform the following: Compare the settlement statement and file ledger and investigate differences. Review closed file for supporting documentation for disbursements over $1,000 listed on the settlement statement. Investigate any unsupported disbursements. Verify disbursement and receipt dates and amount on the file ledger with the bank statement or copies of cleared checks, to determine timely clearance. Verify funds were received/ deposited prior to disbursement. For outgoing wire transfers, verify compliance with Company’s policy for initiation and approval. PASS / FAIL / NA If 20% or more of items tested for any FAIL Procedure 2.06 FAILS. If NA, PASS 2.07* For accounts reviewed in Assessment Procedure 2.03, verify that the Company utilizes Positive Pay or PASS / FAIL / NA