Background Check

A background check is the process of compiling and reviewing both confidential and public employment, address and criminal records of an individual or an organization. Background checks may be limited in geographic scope. This provision and use of these reports are subject to the limitations of federal and state law.

Clean Desk Policy

A company policy requiring that all sensitive information, both in electronic and paper form, be clear from work areas and secure when not in use.


The entity implementing these best practices.

Daily Reconciliation

At a minimum, a two-way reconciliation of the Company's book balance and the reconciled bank balance. If the two components do not agree, the difference shall be investigated and corrected.


A transaction in which an impartial third party acts in a fiduciary capacity for the seller, buyer, borrower or lender in performing the closing for a real estate transaction according to local practice and custom. The escrow holders have fiduciary responsibility for prudent processing, safeguarding and accounting for funds and documents entrusted to them.

Escrow Trust Account

An account to hold funds in trust for third parties, including parties to a real estate transaction. These funds are held subject to a fiduciary capacity as established by written instructions.

Federally Insured Financial Institutions

A financial institution that has its deposits insured by an instrumentality of the federal government, including the Federal Deposit Insurance Corporation (FDIC) and National Credit Union Administration (NCUA).

Information Security Risk Assessment

Documentation noting the (1) Locations, systems and methods of storing, processing, transmitting, and disposing of client information (2) Potential internal and external threats that could result in unauthorized disclosure, misuse, alteration or destruction of Non-public Personal Information or customer information systems (3) Risks associated with identified threats (4) Current security controls in place to mitigate the occurence or impact of identified threats (5) Risk ranking of information systems.


Title Agent or Producer License or registration, or any other business licensing requirement as required by state law, or a license to practice law, where applicable.

Logical Access

This is often defined as interactions with hardware through remote access. This type of access generally features identification, authentication and authorization protocols (i.e. uniquie user ID's, complex passwords, etc.).

Non-public Personal Information

Personally identifiable data such as information provided by a customer on a form or application, information about a customer’s transactions or any other information about a customer which is otherwise unavailable to the general public. NPI includes first name or first initial and last name coupled with any of the following: social Security Number, driver’s license number, state-issued ID number, credit card number, debit card number, or other financial account numbers.

Penetration Test

An independent test designed to achieve a specific, attacker-simulated goal and should be requested by customers who are already at their desired security posture. A typical goal could be to access the contents of the consumer database on the internal network, or to modify a record in the escrow accounting system. The deliverable for a penetration test is a report of how security was breached in order to reach the agreed-upon goal (and often how to remediate).

Physical Access

This refers to interactions with hardware in the physical environment, where equipment is stored and used. Physical access control limits access to campuses, buildings, rooms and physical IT assets.

Positive Pay or Reverse Positive Pay

Any system by which the authenticity of a check is determined before payment is made by the financial institution against which the check is written. Traditionally, this service is offered through your bank.

Segregation of Duties

An organization internal control process and procedure implemented by management to help ensure the reliability of the escrow bank reconciliaions (daily and monthly) performed. The establishment and effectiveness of this control requires all escrow bank reconciliations be performed by a competent individual who does not have check signing or wire disbursement authority.


In some areas called a “closing.” The process of completing a real estate transaction in accordance with written instructions during which deeds, mortgages, leases and other required instruments are executed and/or delivered, an accounting between the parties is made, the funds are disbursed and the appropriate documents are recorded.

Three-Way Reconciliation

A three-way reconciliation is a method for discovering shortages (intentional or otherwise), charges that must be reimbursed or any type of errors or omissions that must be corrected in relation to an Escrow Trust Account. This requires the escrow trial balance, the book balance and the reconciled bank balance to be compared. If all three parts do not agree, the difference shall be investigated and corrected.

Trial Balance

A list of all open individual escrow ledger record balances at the end of the reconciliation period.