The first step is to determine the Company's current level of compliance using Aprio's Compliance Benchmark tool and then to develop a plan to remediate any deficiencies. Aprio has developed its ComplianceSuccess® Program as a fast track to compliance with ALTA Best Practices. Aprio's Compliance Benchmark will enable you to assess your current level of compliance with ALTA Best Practices. Aprio will provide a gap analysis report and a remediation plan in as little as three to five business days. We will review it with you to create a customized plan of action.
The Compliance Benchmark can be completed without any advance preparation. This will give you the most objective evaluation of your agency's current level of compliance using ALTA's Best Practices Assessment Procedures Framework as the benchmark.
The Compliance Benchmark should take no longer than an hour to complete. You may save your answers and exit at any time.
Based on the suggested remediation steps generated by the gap analysis report and how far along your company is in documenting its policies and procedures in accordance with ALTA Best Practices, the remediation phase can take anywhere from a few days to a few months to complete. On average, clients spend two months remediating to ensure they have fully corrected all deficiencies.
ALTA requires that the Company demonstrate compliance with ALTA Best Practices for a minimum period of three months, unless your mortgage lender requires a longer assessment period.
If you encounter a compliance issue or delay in remediation at any time during your assessment period, please notify Aprio immediately. There are no additional fees for changing your assessment period prior to the start of testing.
Once the Company has remediated compliance deficiencies and has been in compliance for a minimum of three months, you are ready to have Aprio begin the testing process.
From the start of testing until the issuance of the compliance report, the entire process takes approximately 3-4 weeks for reviews and 6-8 weeks for examinations. If issues arise during testing or if documentation is submitted late, there may be a delay beyond that timeframe.
As a general rule, it will take approximately one day for reviews and up to three days for an exam to gather the information requested for testing.
This depends on the engagement type selected for your Company. For a review engagement, no onsite visit is required. For examination engagements, an onsite visit of one to three days is necessary, depending on the number of locations and assuming there are common procedures at all locations. The remaining compliance testing will be conducted electronically over a secure network portal and will cause minimal disruption to the daily business of your agency.
Being a part of Aprio's ComplianceSuccess® Program from the beginning reduces the likelihood deficiencies will be noted during the compliance testing stage. If any deficiencies are found during the engagement, we will notify you immediately and discuss your options. You will have the option of using a new assessment period for re-testing. If needed, we will provide a referral for remediation assistance. We will refer at least two independent resources that could help with remediation needs. We will then resume compliance testing once the issue has been resolved and compliance has been demonstrated through the assessment period.
Upon successful completion of testing, your company will receive a CPA attestation report detailing the ALTA assessment procedures performed, and a certificate of compliance from Aprio.
NPI is considered to be any personal and confidential consumer information that does not reside in the public domain. This would include, but not limited to, activity and account numbers pertaining to social security cards, credit cards, loans of any kind (mortgage, car, boat, etc.), investments, medical information, credit reports, paystubs, employment information, background/credit checks, unlisted personal addresses and tax returns.
Submit the completed Excel workbook, including all 9 Tabs of the workbook. Submit all documents that are specified on the instructions Tab of the workbook.
Submit as many documents as possible that you have completed. This will keep you moving through the process. Once we have received all of the documents required for testing, we will review the information you provided. All requested information will need to be uploaded on or before the start date indicated in your engagement letter to ensure that your testing is on schedule.
Tab 1.01 of the workbook should include any and all state bar licenses, department of insurance licenses (individual and entity), title producer licenses, secretary of state registrations & ALTA licenses.
You should include any checks/disbursements (including wires) that seem out of the ordinary compared to a majority of your closing files. These disbursements should agree to the closing file and settlement statement.
Document this within your policies and procedures and state that if Positive Pay does become available, you will utilize the service.
Please see following document for guidance on this topic: Guidance on Pillar 3.03 and Pillar 3.04 document
If you performed less than 25 residential closings during the assessment period, please test 100% of your residential closings on Tabs 4.01-5.01 of the Excel workbook. Also, be sure to indicate to Aprio that this is the complete list of all residential closings performed during the assessment period.
There may be extenuating circumstances in certain states that will not allow deeds to be sent to the county recorder within two days, such as split closings, tax stamps, etc. If this is the case for any closings in your sample, please provide the date on which all commitments were met to be able to send the deed for recording.
Examples of non-title insurance rates include settlement fees, closing fees, title search, recording fees, shipping fees, etc.
The correct portion of the premium collected must be remitted to the underwriter in accordance with applicable statutory, regulatory and contractual obligations. Ensure that payment terms are defined in your agency agreement with your underwriter and that you are remitting premiums in accordance with those terms.
Include all insurance requirements that are mentioned in each underwriter agreement such as errors and omissions, fidelity bonds, surety bonds, etc.
This is a compiled listing of all your complaints into one specific document that includes whether a resolution is necessary, how it was resolved, and the date that it was resolved.
You will need to document complaints that you received prior to the implementation of the log and add them to your new complaint log to ensure your complaint log covers a period of 12 months preceding the assessment period end date.
This is the person or department that is responsible for receiving complaints and following through with the complaints from start to finish. Ensure that you have designated a single point of contact for complaints in your Policies and Procedures manual.
You will still need to have a consumer complaint log in place just in case a complaint were to occur. Please provide a copy of your blank complaint log and indicate to Aprio that there were no complaints for the period of 12 months immediately preceding the assessment period end date.