Pillar 6 – Professional Liability Insurance

6.01 Professional Liability Insurance and Fidelity Coverage

The Company maintains appropriate insurance to assure the financial capacity to stand behind its services, including complying with any applicable insurance requirements under state law and/or underwriting agreements.

Applicable parties: Management, Operating Accounting, Corporate Admin

6.01(a) Establish Professional Liability Insurance and Fidelity Coverage

ESTABLISH INSURANCE

(1)Identify minimum insurance requirements (e.g. E&O, Fidelity, Surety Bond, Notary) on Company Tracking Log.

(a)State (e.g. Department of Insurance website, Attorney licensing website)

(b)Underwriter (UW Agreements)

(c)Customer (Business Source Contracts/Service Level Agreements)

(2)Document minimums for items below on Company Tracking Log.

(a)E&O/Professional Liability

(b)Fidelity Insurance/Indemnity Fund

(c)Surety Bond (note risk factors: scope of ops, volume, offices #, employees and controls)

(d)Third Party/Independent Contractors (TPSP Tracking Log)

(3)Apply for coverage using established minimums.

(a)E&O/Professional Liability

(b)Fidelity Insurance/Indemnity Fund

`(c) Surety Bond

(4)Verify that E&O/Professional Liability covers all professional services offered by the Company

(a)Title Agent

(b)Title Abstractor

(c)Searcher

(d)Escrow Officer

(e)Settlement Agent

(f)Foreclosing Agent

(5)Obtain proof of or apply for appropriate coverage for independent contractor providers, as appropriate, and store copy in a single physical and/or electronic location.

(6)Verify insured name listed on the E&O/Professional Liability or named insured endorsement matches the name on contracts and underwriting agency agreement(s), including any applicable DBA’s.

(7)Upon approval, add necessary information to Tracking Log.

(8)Place a copy of coverage in a single location.

Evidence: All required Bonds and Insurance either meet or beat minimum requirements by State of Texas or GATCO's underwriters. Current bonds and policies available upon request.

Applicable parties: Operating Accounting, Corporate Admin, Management

6.01(b) Maintain Professional Liability Insurance and Fidelity Coverage

Maintain Insurance - Annual

(1)Perform an annual review to determine the current legal minimum of insurance requirements with appropriate state entities (e.g. department of insurance, department of financial services websites)

(2)Evaluate coverage(s) based on risk factors such as:

(a)Scope of operations

(b)Volume of transactions

(c)Number of offices and employees

(d)Internal controls and procedures

(3)Update new established minimums, if any,

(4)Include updates in Company Tracking Log

(5)Repeat steps to “Establish Insurance”

Maintain Insurance - Monthly

(1)Perform a monthly review of all insurance coverage(s) for any that may be expiring within the next 30 days

(2)Identify any coverage that is expiring and renew

(a)Follow steps to “Establish Insurance”

(3)Update any applicable coverage(s) with any new hire or termination or new professional services contractors from the previous review period

(4)Update Company Tracking Log

All Bonds and Insurance Coverage are logged and maintained on a daily basis. All current policy and bond coverage is available upon request.

Evidence: Company Tracking Log (Available upon written request)

Applicable parties: Operating Accounting, Corporate Admin, Management