Pillar 4 – Settlement Process

4.01 – Recording Documents Policy

The Company complies with legal and contractual requirements for recording documents.

4.01(a) – Recording Documents Procedure

The Company submits documents for recording within two (2) business days of the later of (i) the date of Settlement or (ii) the receipt of the documents by the Company if Settlement is not performed by the Company.

Evidence: Recorder’s Receipt is stored in each Guaranty File (Available upon written request)

Applicable parties: Escrow Personnel

4.01(b) – Verify Timeliness

The documents to be recorded and date/time of submission for recording are noted in the file. Recording status is verified by one of the following methods:

(1)If recording information is available online, status is checked online every 48 hours.

(2)If recording information is not available online, status is checked by in-person search or other means every 72 hours.

(3)If electronic reporting ("eRecording") is used, confirm documents were promptly recorded via the eRecording system.

(4)Branch Management or Post Closing reviews the files monthly to verify that documents are submitted for recording within the required time periods. Reports are to be submitted to Branch Manager and President.

Evidence: Recorder’s Receipt is stored in each Guaranty File (Available upon written request)

Applicable parties: Escrow Personnel

4.01(c) – Recording Information Retention

The Company retains document recording information, including date and recording number, in the file with which the document is associated, electronically or on paper.

Evidence: Recorder’s Receipt is stored in each Guaranty File (Available upon written request)

Applicable parties: Escrow Personnel

4.01(d) – Verify Compliance with Legal and Contractual Requirements

The Company maintains a spreadsheet that notes more restrictive recording requirements as follows:

(1)The type and date of the resource containing the more restrictive recording requirement is inserted into the spreadsheet. Examples are a lender’s instructions, state statutes, or agency agreement.

(2)The recording requirements contained in the resource are inserted into the spreadsheet.

Evidence: There are currently no special recording requirements in place.

Applicable parties: Management

4.01(e) – Rejected Documents Procedure

The Company addresses rejected documents within two (2) business days of receipt of the rejected documents by promptly forwarding the rejected documents to the escrow officer responsible for recording those documents, or manager if the escrow officer is unavailable.

Evidence: Recorder’s Receipt in Guaranty Files (Available upon written request)

Applicable parties: Escrow Personnel

4.01(f) – Resubmitting Rejected Documents Procedure

The Company investigates and resolves the reason(s) for the document rejection promptly, and resubmits rejected documents within thirty (30) days of receipt of the rejected documents. The resubmission date/time is noted in the file.

Evidence: Recorder’s Receipts in Guaranty File and any possible special notes by Escrow Officer in charge. Available upon written request.

Applicable parties: Escrow Personnel

4.02 – Established Rates Policy

The Company’s charges comply with current filed or promulgated rates, endorsements, and/or rates established by the Company’s title insurance underwriters or rating bureau in each state where the Company does business. Where overpayments occur, refunds are issued upon discovery.

Evidence: Billing Statements from Underwriters (Available upon written request)

Applicable parties: Escrow Personnel, Management, Operations Accounting, Policy Production, Corporate Admin

4.02(a) – Established Rates Status Procedure

1)For every location where the Company conducts business, the established rates are determined and noted on a spreadsheet. Discounted rates, including reissue rates, are included, as applicable. Non-title insurance rates for services provided by the Company are included.

(2)At least annually, management reviews 25 files or 100% of the last 3 months of closed files, whichever is less, The title policy production department shall review all closed files to ensure the charges for each file comply with the established rates.

(3)Refunds are issued immediately upon discovery. The refund amount, payee, date of refund, and reason for refund are noted in the file. and in the Employee Training documentation.

(4)At least annually, training is conducted for employees on the proper determination of rates. Should the title policy production department discover an inappropriate calculation of the title premium, the title policy production department will contact the appropriate escrow employee and inform and train them on how to eliminate future errors.

Evidence: Great American Title Company’s Title Calculators

Applicable parties: Branch Escrow Managers

4.03 – Third Party Signing Procedures

See Closing Outside of Owning Office Branch Policy

Details of Amendment

This document hereby amends Pillar 4 – Settlement Process as follows:

4.01(b) – Verify Timeliness (number and name of section) is changed to read:

(4)Branch Management or Post Closing reviews the files monthly to verify that documents are submitted for recording within the required time periods. Reports are to be submitted to Branch Manager and President.

4.02(a) – Established Rates Status Procedure (number and name of section) is changed to read:

(2)At least annually, management reviews 25 files or 100% of the last 3 months of closed files, whichever is less, The title policy production department shall review all closed files to ensure the charges for each file comply with the established rates.

(3)Refunds are issued immediately upon discovery. The refund amount, payee, date of refund, and reason for refund are noted in the file. and in the Employee Training documentation.

(4)At least annually, training is conducted for employees on the proper determination of rates. Should the title policy production department discover an inappropriate calculation of the title premium, the title policy production department will contact the appropriate escrow employee and inform and train them on how to eliminate future errors.

(Cut and paste text from the policy PDF, making the changes required. It is sometimes good practice to highlight the changes with italics).

Except as specifically stated above, all other provisions of the company’s Pillar 4 – Settlement Process remains in effect. The changes detailed herein are effective immediately on the authority of the undersigned.