Great American Title Company is hereinafter referred to as "the company”.

1.0 Overview

The handling of Customer Complaints is very important to the future of the company as well as to the disgruntled customer. Complaints are to be taken very seriously by all parties involved.

2.0 Scope

The scope of the subject procedure is the establishment of general rules and procedures for the handling of Customer Complaints. Complaint should be considered as any expression of dissatisfaction by or on behalf of a client about provision of, or failure to provide an excellent title or escrow service by GATCO which; alleges financial loss, regulatory/compliance breach or any other material problem or presents a title or escrow claim against the Company, is handed by the Customer, or on behalf of the Client, regardless of source or method of submission.

3.0 Proper Handling

Proper handling of customer complaints is of paramount importance, since it safeguards the legitimate interests of customer and as a consequence:

•The Company’s good reputation is protected

•The Company avoids possible civil actions by customers.

4.0Procedure

Customers who are willing to present a complaint to the Company should be:

•Verbally informed that the complaint is considered to be presented only if the Customer Complaint Form is handed by the Customer or on behalf of Client to any branch of the Company or has been sent by mail or received at e-mail address complaints@greatamtitle.com

•Told the name and the contacts of the Branch Manager or Executive Officer with whom the Customer can communicate with regarding any enquiries about the complaint.

4.1Complaints through GATCO Website (Feedback Section)

In cases when the complaint is received through the GATCO website, the Company shall immediately, but not later than the next business day send a message (receipt) to

the Customer’s e-mail address from which the complaint has been received mentioning the date on which the complaint has been received.

4.2 Complaints that are Hand or Email Delivered

In cases when the customer Complaint Form is hand delivered or emailed to an employee of the Company, the employee should assure that the Customer Complaint Form is fully completed and informs the customer complainant in person or by email that management will contact them immediately, but no later than the next business day.

5.0Remedies

•Customers who believe that the service(s) offered to them are not of a sufficiently high quality or that there is something wrong in their relationship with the Company, can bring the issue to the attention of the Company’s relevant staff.

•You are encouraged to deal with a complaint as soon as a customer mentions their dissatisfaction, and must try to resolve the complaint immediately. A clear distinction must be made between complaints which allege financial loss, material distress, title or escrow loss and material inconvenience, and complaints arising from a minor error which can be remedied promptly. There is no requirement to follow these procedures where the complaint has not resulted in any financial loss, title or escrow loss, material distress or material inconvenience, but is the result of an administration error which can be classified as minor and has been resolved to the satisfaction of all involved parties within 48 hour period.

•However, if a complaint cannot be resolved easily within 48 hours the Customer should be contacted and offered to present a written complaint according to the current procedure.

•Customer complaints should be investigated thoroughly and promptly by an independent person, as they may indicate that service/procedural deficiencies or ineffectiveness have arisen. Another important reason for paying good and prompt attention to customer complaints is that they may be the first indication of serious irregularities or fraud.

6.0Documentation

6.1Complaint Register

As a general rule all complaints should be handled by the employee responsible for processing the enquiries addressed to the Company. There may be separate cases when complaints may be handled by the respective Branch Managers receiving the complaint. An employee must never handle a complaint made against him/her. The employee responsible for the handling of the complaint should complete the Complaint Register, which should include:

•Name/Guaranty File Number of the complainant,

•Date when the complaint has been received,

•Substance of the complaint

•Name of the employee responsible for the complaint handling

•Any correspondence between the Company and the complainant, including how the complaint was resolved

•Any reimbursement offered by the Company, how it has been calculated and the response of the complainant to this offer

•Date of the Company’s response

6.2Legal Counsel

Where litigation is threatened or instigated, an Executive Officer and/or in-house Legal Counsel should be informed as early as possible and advice sought.

6.3 Employee Handling

Employees responsible for complaint handling must:

•record the complaint in the Customer Complaint Log

•try to resolve the complaint and arrange the response to the customer as soon as possible

•make all efforts to resolve the complaint within 10 business days from the date of the receipt

•if the complaint is not resolved within 10 business days, correspondence should be sent to the Customer, which should include the reasons for the delay and the date of the final response.

The outstanding complaints must be reviewed weekly by the immediate supervisor of the employee involved. All outstanding issues over 10 business days must be notified to the Company’s respective business heads.

6.4 Unnecessary Documents

While receiving or processing the complaint the Company cannot request from the customer any document that:

•is not required for the justification of the complaint or any underlying circumstances or for the identification of the customer, or

•is available to the Company as a result of providing services to the customer and the information stipulated is not changed as per customer’s written request.

6.5Responses

The responses to the Customers should be sent to the addresses or via telecommunication means mentioned by them. The final response sent to the Customer by the Company should include the following information:

•The Company’s explicit position to satisfy, partially satisfy or to decline the complaint,

•The reasoning for the decision,

•The name and contact information of the employee responsible for the handling of the complaint,

•Information that in case of any questions regarding the outcome of the complaint

•The Customer can contact the responsible employee,

•Information, that if not satisfied by the written response the Customer in order to protect his/her rights can file their complaint with the Texas Department of Insurance or with the appropriate title insurance underwriter, underwriting their transaction.

6.6Review of Complaints

The Complaint Log must be reviewed on a quarterly basis by the Executive Management of the Company to ensure that all customer complaints have been resolved and/or outstanding complaints are being dealt with.

7.0 Enforcement

This policy will be enforced by the Manager and/or Executive Team. Violations may result in disciplinary action, which may include suspension, restriction of access, or more severe penalties up to and including termination of employment. Where illegal

activities or theft of company property (physical or intellectual) are suspected, the company may report such activities to the applicable authorities.

8.0 Revision History

Revision 1.0, 10/13/2012

Revision 2.0, 09/01/2014