3.17* Obtain and inspect policies and procedures over record retention and disposal. Verify procedures are PASS / FAIL in place for disposal of Non-public Personal Information. If any individual FAILS, If document/electronic media disposal services are Procedure 3.17 FAILS. provided by a third party, obtain evidence of the contract agreement/SLA and a recent document disposal certificate from the vendor. Assessment ALTA Best Practices Framework: Assessment Procedure Assessment Recap Procedures Number Overall Assessment ALTA Best Practice 4 Recap: If any standard real estate settlement procedures individual and policies that help ensure compliance with marked with an Federal and State Consumer Financial Laws as asterisk FAILS, Best applicable to the Settlement process. Practice 4 FAILS. 4.01* Obtain and/or document Company’s written PASS / FAIL / NA procedures to maintain compliance with established If no written rates and legal and contractual requirements for procedures, Procedure recording documents. 4.01 Sample Sample Selection for Assessment Procedures 4.02 Selection and 4.03: Instructions on Company’s process (centralized versus for decentralized), select sample as follows: Next Two Centralized: Assessment 25 files or 100% of last 3 months of Procedures closed files, whichever is less. Decentralized: At least 1 file per state in which Company writes (a minimum of 25 files in total) or 100% of last 3 months of closed files, whichever is less.
3.17* Obtain and inspect policies and procedures over record retention and disposal. Verify procedures are in place for disposal of Non-public Personal Information. If document/electronic media disposal services are provided by a third party, obtain evidence of the contract agreement/SLA and a recent document disposal certificate from the vendor. PASS / FAIL If any individual FAILS, Procedure 3.17 FAILS. Assessment Procedure Number ALTA Best Practices Framework: Assessment Procedures Assessment Recap ALTA Best Practice 4 standard real estate settlement procedures and policies that help ensure compliance with Federal and State Consumer Financial Laws as applicable to the Settlement process. Overall Assessment Recap: If any individual marked with an asterisk FAILS, Best Practice 4 FAILS. 4.01* Obtain and/or document Company’s written procedures to maintain compliance with established rates and legal and contractual requirements for recording documents. PASS / FAIL / NA If no written procedures, Procedure 4.01 Sample Selection Instructions for Next Two Assessment Procedures Sample Selection for Assessment Procedures 4.02 and 4.03: on Company’s process (centralized versus decentralized), select sample as follows: Centralized: 25 files or 100% of last 3 months of closed files, whichever is less. Decentralized: At least 1 file per state in which Company writes (a minimum of 25 files in total) or 100% of last 3 months of closed files, whichever is less.
CFPB%20-%20CTNC%20Presentation%20Materials%209-22-13.docx