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  • 10/13/2021 3:21 PM | Scott Merritt (Administrator)

    Washington, D.C., Oct. 13, 2021 — The American Land Title Association (ALTA), the national trade association of the land title insurance industry, announced that the ALTA Registry, the national database of title and settlement agents, added a new feature that allows companies to quickly provide errors and omissions (E&O) policy information to underwriters. 

    The new feature allows title and settlement companies to upload their E&O information to the ALTA Registry. Underwriters can then access the data to quickly verify the information. This new tool includes document level automatic scrubbing using Deep Secure by Forcepoint’s malware removal technology and data extraction via AREAL’s artificial intelligence powered document processing technology. 

    “The ALTA Registry has evolved into a data clearinghouse for title underwriters, lenders and settlement agents,” said Jack Rattikin III, CEO of Rattikin Title and co-chair of the ALTA Registry Committee. “The Registry provides an optimal way for underwriters to manage oversight of their agents’ E&O data.” 

    Nearly 8,800 title agents, settlement companies and real estate attorneys appear in the ALTA Registry. The ALTA Registry allows title insurance agents and settlement companies to communicate with underwriters to confirm their company name and contact information—providing mortgage lenders with a trusted industry online database to identify transaction partners. 

    The ALTA Registry also closes an access point for potential malware and drives down oversight costs by improving accuracy and automated data downloads.  

    “A secure and neutral data-sharing utility that benefits all title agents and underwriters will be a welcome solution to maintaining current E&O coverage details,” said Eddie Oddo NTP, vice president of Corporate Business Solutions for First American Title Insurance Company and co-chair of the ALTA Registry Committee. “The Registry standardizes the process and eliminates the need for title agents to send E&O information to multiple underwriters, allowing industry professionals to focus on the tasks that drive their business.” 

    The ALTA Registry confirms that mortgage lenders are working with the correct title agent, settlement company or real estate attorney. Every title agent office location is identified by a unique ALTA ID, allowing quick verification. Each entry is also fully confirmed by title insurance underwriters. Using the ALTA Registry, mortgage lenders can increase accuracy, reduce production expenses, combat fraud and improve compliance. The ALTA Registry is offered to mortgage companies on a subscription basis. 

    Last year, the Registry added an indicator to designate title and settlement companies that can perform remote online notarization (RON) closings. This helps mortgage companies identify closing companies that allow homebuyers to review, sign and notarize documents online.
  • 09/15/2021 1:15 PM | Scott Merritt (Administrator)

    an article by the Cyber Security Committee

    In a world of smart phones, computers, laptops, tablets, Alexa, Siri…. Do you ever wonder if your devices are listening to you? That perhaps your “private” conversations aren’t so “private” after all?

    The short answer is “Yes”, these devices have the ability to listen to you and in many cases, they are. Facebook, Google, and Amazon are just a few of the companies that are listening and collecting information, not to mention cybercriminals who are potentially listening in on your smart devices. After all, the device itself may not be recording this information, but once a cybercriminal has access, the fraudster could be recording this information.

    As more and more of us continue to work remotely, away from corporate security overlays, it is important for you to think about the conversations you are having while using these types of devices. For example, consider:

    1.   Are you discussing sensitive transaction information with a client or customer?

    2.   Are you in meetings discussing proprietary company information?

    3.  What about the personal conversations you may be having about your health issues or other personal matters?

    You may feel safe discussing this kind of information in the privacy of your own home, but always keep in mind that these conversations, and especially the information disclosed, may not be as safe as you think!  So, what can be done?

    Here are some security tips to consider to keep your private conversations as safe as you can!

    • A.  Turn off microphone access to all third-party apps (such as Facebook) in the Settings on your smartphone:
    • o   iPhone: Go to Settings > Facebook (or any other app) > slide the toggle next to the Microphone to the left, so it turns from green to white.
    • o   Android:  Go to Settings > Applications > Application Manager > look for Facebook (or any other app) > Permissions > turn off the mic.
    • B.  Assume every app is corruptible, and that anything you download can be used against you.
    • C.  Never download an app from outside of the App Store.   There are numerous fake app sites that use “click” bait to gain access to your devices.
    • D.  Be aware of where your electronic devices are located in your work space.  Remove or isolate them from “hearing” as a precaution when appropriate.
    • E.  Turning your cell phone off and then back on (rebooting) at least once a week.  This helps to prevent hackers from accessing personal information. According to the National Security Agency (NSA), this simple weekly action can make personal devices more secure and make it harder for criminals to steal data. Rebooting a phone is a quick and easy way to make it more difficult for these criminals to make you their next victim.

    The most important thing to remember is that your personal devices are akin to mini-computers.  Gaining access to them allows the cybercriminals to access a great deal of personal information that can ultimately be used on the black market against you and your employer.  Employing a few safety tips such as the ones mentioned above are easy ways to help safeguard your privacy.

  • 06/03/2021 9:46 AM | Scott Merritt (Administrator)

    Where are your Secrets being Kept?

    Printer Risks/Vulnerabilities

    Article by the Cyber Security Committee

    Office printers/scanners/fax machines (hereinafter “printers”) are a treasure trove of sensitive data. Because they often come with a web-based interface or an internet connection, they have a huge attack surface, making them easy to hack.

    How are printers vulnerable?

    • Open External Ports (USB, memory cards, etc.)
    • Wi-Fi, Bluetooth and other wireless connections
    • Printers have a memory – all items printed, scanned and copied are stored in memory on hard drive of printer

    What do hackers want with printer access?

    • Access to Non-Public Personal Information and other sensitive information
    • Backdoor access to network – printers can become a “hot spot” for others to use your internet access which could compromise your data and slow the speed of your Wi-Fi

    What are common methods of attack?

    • Criminal sending an image of a file to a company’s printer with Trojan malicious code, which can allow them to capture the content of all images that are printed
    • Criminal will change printer configuration to re-route print jobs to outside the company
    • Criminal will attack through Wi-Fi by getting the printer to connect to a malicious network and then execute/install harmful code

    Steps/suggestions to protect your printers:

    • Change the password access to printer regularly
    • Consider having all employees have their own long, unique passwords
    • Change the printer’s name
    • Change the printer’s Wi-Fi password
    • Regular updating with security patches and software
    • Regularly update and upgrade your printer for latest in security features 
    • Consider disabling USB port on the printer
    • Turn off all application options that come pre-configured with your printer
    • Turn on dual 2-factor authentication, if available
    • Turn off “notifications” for proactive maintenance being sent to suppliers (any messaging going outside your company is taking a risk)
    • Configure network settings so that the printer can only answer commands that come from specified ports on your network router
    • Use a firewall on your printer
    • Enable the hard disk setting to encrypt/set to overwrite
    • Consider turning off all Wi-Fi or Bluetooth options
    • Awareness is key - Recognizing the risk that printers have and making it a priority is crucial in managing and mitigating these threats

     Special considerations to protect your printers AT HOME:

    • Shred all sensitive information that you print at home office prior to throwing it away
    • Update your driver when prompted 
    • If you get rid of a home printer, destroy the hard drive or change the printer settings to make sure that the hard drive is not storing any information
    • If using Wi-Fi – make sure you have a secure connection using VPN - Consider hard wiring if possible
    • Disable Internet Printing Protocol (IPP) printing and enable Secure IPP printing instead
    • Make sure your wireless security is WPA2 or stronger
    • Change setting and redirect to https
    • Set encryption strength to high

  • 03/15/2021 3:37 PM | Scott Merritt (Administrator)

    An article from the FLTA Cyber Security Committee


    A.  Initial Phone Call to Consumer in the beginning of the transaction:

    • Verbally confirm that the request to initiate the wire is from an authorized person within the title company and inform them that the wire instructions will not change.
    • A cashier’s check, a certified check or a wire transfer is acceptable to bring to closing. Many title companies today will only accept wire transfers and limit personal checks to no more than $500, but please be sure to check with your title company regarding their policies for accepting funds.
    •  Communicating directly with title company:  Secure transmittal of documents and information
      • Some title companies will utilize a portal for sharing documents and information.  A client portal is a website, web application or mobile device which provides businesses a secure storage space to let all parties share important documents or information related to the closing process.
      • Use of secure and encrypted email is a best practice today.  Regular un-encrypted emails are easily read by anyone, regardless of whether that person was the intended recipient or not. With secure email encryption, individuals and enterprise systems render the contents of the message unreadable as the email is sent from origin to destination. Most encryption requires a password to access the information in the email.
      • Contact the closing company via the phone number listed on their internet website or call the direct line that you have been using throughout the process and especially on day of the wire transfer.  Never use the phone number listed on an email.  If someone whom you have not spoken with from the title company calls you to verify personal information, get your social security number or verify wiring instructions inform them you will call them back and use the phone number from website or direct line.
      • Verbally confirm wire instructions directly with the title company where you are closing. Be alert and speak directly with the title company if you suspect any email, text compromise or suspicious activity related to your closing.


    A.  Speak with Realtors at the beginning of the transaction: How are we communicating with them?

    • Understand your realtor’s means of communication
      • Communication takes the lead in most things that you do during the closing process. Effective communication goes beyond saying a couple of things and assuming that you are on the same page with your realtor partners. One important consideration is finding how the realtor likes to interact and following a preferred method. Most realtors today like to communicate by email or even text messaging. There are some folks that would like you to pick up the telephone to call. Some are tech savvy and prefer to use another mean of communication. It is best to set proper expectations with your realtor at the beginning of the transaction to avoid any miscommunications.
    • Consider using a portal for communication
      • Some title companies will utilize a portal for client communication. A client portal is a website, web application or mobile device which provides businesses a secure storage space to let all parties share important documents or information related to the closing process.
      • With the client portal, customers don’t have to reach out to the company for each item in a transaction This creates less strain on the company, as they don’t have to answer the phone call or get engaged in any type of real-time conversation.
      • Although client portals are more secure than email, many businesses have a concern about the security of their data in the cloud. These types of businesses can opt to have a private cloud for their sensitive data and take the on-premises hosting of software.
    • Telephone verification on the day of the wire transfer
      • Verbally confirm the request to initiate the wire from an authorized person within the title company.
      • §  Contact the closing company via the phone number listed on their internet website or call the direct line that you have been using throughout the process, especially on the day of the wire transfer.
    • Create a standard warning document about wire fraud and other real estate scams
      • You may wish to consider adding a warning to your email signature line on wire fraud. This notice should not serve as a substitute for educating your clients and other participants in your real estate transactions about email wire fraud.
      • Provide a document that informs your Buyers and Sellers of wire fraud: what it is, how it occurs and how to protect yourself from it.

    B.  Email discussion with Realtors  

    • Open email system:
      • An open email system provides visibility to all team members.  From a business perspective, the open system is a great convenience for sharing information and coordinating business process functions, but it also creates significant security risks because of the lack of privacy that is the essence of its very nature.  The more people who have access, the more exposure to risk. 
      • Additionally, email, itself, is an open format because it can be viewed by anyone who can intercept it (i.e. hackers), despite whether the system is intentionally designed to be shared among team members.
    • Compare to secure email:
      • Today, there are two main protocols used for encrypting emails: TLS, encrypting an email while it’s in transit and End-to-end email encryption.  Encrypted email technology is meant to render the content of your emails unreadable as they travel from origin to destination.  For emails that hold highly sensitive information it is best to use End-to-End encryption. It is designed so that the content can only be decrypted by the intended recipient on their device. While TLS provides strong protection against attacks, the emails are still only secure when they are in transit. Take precautions to preserve privacy, and do not copy other service members on the email, as this could lead to compromising sensitive information or attachments related to the file.
    • Tools to secure email:
      • There are various technology tools available for purchase to create an encrypted email environment, such as automation and digital signatures. However, there are also some very simple steps to take, as well as free or low-cost tools available, to help secure your email:
      • Do not share a common email account with anyone else
      • Use strong passwords; change email passwords frequently, especially before sending out wiring instructions
      • Employ a unique and not easily reproducible email name
    • Email Hosting Services for secure email
      • When using a common email platform, like Gmail or Yahoo, it is relatively easy for a fraudster to impersonate another’s email; after all, anyone can sign up for a free Yahoo or Gmail account.  By changing one solitary letter in a free account email name, a hacker has an excellent chance of passing himself or herself off as the authentic sender – particularly when the recipient does not look too closely at the spelling of an expected email. 
      • An alternative is to use an “email hosting service,” such as Go Daddy, to purchase a specific, unique domain name for your email that cannot be impersonated (e.g.  These services have a variety of options, such as a landing page (i.e. a webpage that subscribers are directed to after filling in fields for contact), and encryption. 
  • 02/25/2021 3:48 PM | Scott Merritt (Administrator)

    Aaron Davis flew from Tampa, Florida, to Austin, Texas, on Friday — because he wanted to help people affected by the snow and ice storm.

    Florida Good Samaritan Dubbed 'Tampa Chainsaw Man' Helping Texans in Deep-Freeze Crisis"I just felt incredibly guilty sitting down in Tampa, Florida, in the sunshine watching the rest of the country suffer," Davis, 45, tells PEOPLE. "I've weathered many storms in my life in Florida, the hurricane capital of the world."

    During the last Florida hurricane, he bought and delivered generators to people in need. "I just try to step up and do what I can," he says.

    A business owner (his company does remote real estate closings), Davis told his staff he was taking a month off to volunteer in Texas. "I felt the need to be feet on the ground in Texas to help out however I could," he says.

    Read the complete story on People Magazine.

    Through Aaron's work with the Harper, TX Fire Department a GoFundMe account has been created calling for funds to assist the community. Aaron has gone on to say, the need is absolutely real and any amount will be a great help.

    GoFundMe Account: Harper Winter Storm Disaster 2021.

  • 02/25/2021 3:36 PM | Scott Merritt (Administrator)

    Dear fellow members,

    I would like to start this message by acknowledging the steady leadership and excellent work of our association staff, our Board of Directors (BOD), and everyone who is contributing so significantly with our various committees and working groups.  A quick review of the other sections of this Newsletter will reveal the current efforts and priorities of our Association being powered by our industry’s most dedicated professionals.  Despite the incredible challenges of the current pandemic, I am very grateful and proud that our Association is in a stronger position at this moment, both financially and structurally, than it was before the pandemic hit us around this time last year.  And we have big plans and opportunities to continue our success. 

    A big focus for this coming month will be our first fully virtual Lobby Days.  Those of you that have participated in past years already know that Lobby Days has become one of the most important and impactful events of our Association as we generate awareness and engagement between FLTA members and key policymakers around current Association legislative priorities and promote the overall benefits that the title insurance and real estate settlement industry provides.  And now this event is open to easier access and more participation by being virtual.  Are you interested in participating?  Get more specific details and register

    Another big focus that I would like to highlight starts with the charitable action of past BOD member, Aaron Davis, who has travelled to Texas to help with the natural disaster caused by their recent storm.  Our Association was inspired by Aaron’s efforts and has contributed $250 to the Harper, TX, Fire Department GoFundMe Account and we encourage any interested members to contribute individually as well.   I know that giving back is an integral part of who we are as individuals, and I am very proud that our Association is evolving in a way that will put formal structure and resources around these efforts.  What started with our BOD decision to donate $20,000 to be split between five Florida area food banks with  increased demands created by Covid-19 and a call to action for our members that was met with so much enthusiasm has now evolved into formal BOD approval to establish an FLTA affiliated Charitable Action Foundation with 501(C)(3) status and a commitment to strengthening the communities where our members live and work. 

    We envision our foundational philanthropy will not be simply about writing a check.  This new organization will put structure around our ongoing relationships, collaborations, shared missions to serve our communities, and the giving of our time and talents to specific need driven challenges as well as the broader long-term goals.   Our Foundation will heighten our Association’s identity internally and externally.

    The scientific research, and the development and rollout of vaccines gives us hope that the dark and isolating days of this pandemic are numbered.  And in its wake, we will have an opportunity to connect in ways both old and new in order to advance the interests of our title insurance and real estate settlement industry in Florida and to serve our communities better than we have before.

    I hope this newsletter contains information that is helpful for you and that you are also proud and engaged in our Association.  Your ideas, comments and questions are always welcome!  I can be reached at


    Len Prescott, 2020-2021 President

  • 02/05/2021 11:11 AM | Scott Merritt (Administrator)


    Wells Fargo

    Settlement Agent Communications

    News for Wells Fargo Settlement Agents

    January 21, 2021


    This newsletter edition contains a combination of both new and updated information, along with a few reminders worth repeating.

    Closing process updates

    Continuous process improvement is an important part of our business to enhance the customer experience, while improving efficiency and quality. Following are several examples of process improvements you will begin to notice in our closing process as these changes are implemented in phases over the coming months:

    • Delivery of the borrower Closing Disclosure (CD) to our customer earlier, at a more consistent point in the loan process.

    System changes will trigger the initial Closing Prep Package delivery and notify the closer to initiate the CD collaboration when pre-requisite loan processing actions have been completed. As soon as the CD collaboration with the settlement agent is successfully completed, the CD will be delivered to the customer. Settlement agents should see earlier requests to initiate CD collaboration, and fewer rush requests.

    • Auto-populated email templates for use by closers to communicate critical loan information to settlement agents nationally.

    Email templates for consistent communication of required loan information will be used by all closing teams. Manual data entry is eliminated. Settlement agents should see increased consistency and accuracy in these communications for all loans. Note: Managed vendors should continue to follow defined communication processes.

    • Consistent and timely notification of transaction changes.

    System changes will notify the closer when there is a change in the transaction that impacts the CD, loan documents, or any other aspect of the loan closing. This will reduce potential delays for closers to be notified of or detect changes. Settlement agents should see a reduction in last minute change notifications.

    • Improvements to enable a more timely delivery of the loan documents for closing.

    The closer's ability to release loan documents is sometimes blocked by deferred approval conditions, expiring documents, etc. Process changes will prevent loans that are not clear to close from being prematurely scheduled for closing, and will increase oversight of loan document delivery timing. Settlement agents will see improvement in the timing between scheduling and delivery of loan documents, and fewer closings needing to be rescheduled due to delayed loan documents.

    Title order response timing

    Fast receipt of the title commitment* is important to expedite the loan process for on-time closings. Wells Fargo's expectation for return of the title commitment is within 5 business days after the title order is placed. For title commitments not received within this timeframe, our follow up process has been enhanced to include the following:

    • Follow up emails are generated from for all title commitments not received within 5 business days following the order date. Follow up emails will also include other outstanding title-related documentation, such as the closing protection letter, where applicable.
    • Emails are now sent twice weekly, on Tuesdays and Thursdays. All outstanding documents for the same settlement agent location will be batched into a single email. This reduces the number of follow up emails being sent to your company or firm.
    • If the outstanding documents have not been received after 2 follow up attempts, a representative from the Title Order team will contact you by phone. These contacts will repeat every 3 days until the documents are received.
    • Documents should be delivered to
    • Managed vendors should continue to follow defined processes for delivery of these documents through the Black Knight Exchange.

    For new construction transactions, the title order timing is aligned to the targeted date for construction completion and closing, but once the order has been placed the same timing expectations and follow up process will be applied.

    While most title commitments can be reviewed and cleared quickly upon receipt, unexpected title issues can quickly derail a closing when they are detected late in the process. We appreciate your focus on title commitment turn times, and hope that the information in the follow up reports is helpful to you.

    *For Iowa properties, this same follow up process applies to Iowa Title Guaranty orders.

    COVID-19 related reminders

    Thank you for the innovative options provided for customers to continue to close their loans as safely as possible. Please continue to ensure that anyone who comes in contact with a Wells Fargo customer for closing — including notary signing agents you engage to meet with customers outside of your office — wears a mask and takes all applicable precautions to protect customers and colleagues.

    Please also continue to protect our customers' rights to protect the privacy of their health information. Note that Wells Fargo cannot accept or retain any personal health information in our loan file, including any health questionnaires. If we become aware that a customer is not able or willing to proceed with a closing due to health concerns, we will not request an explanation.

    While the frequency of recording delays has been reduced, we continue to see examples due to a county recorder office that is closed or with reduced capacity related to COVID-19. When this occurs, Wells Fargo will allow the loan to close subject to the following:

    • Title insurance gap coverage effective from the date of consummation (the date the Note is signed) to the date of recording. Gap coverage that does not take effect until the date of recording will not be accepted.
    • There can be no exceptions to coverage in Schedule B pertaining to COVID-19 or the county recorder closing/delay. If the commitment includes an exception requiring the borrower to sign an indemnification agreement, an updated title commitment or other documentation evidencing that this has been satisfied will be required.
    • Wells Fargo will not sign any indemnification agreement required by the title agent or title underwriter as a condition for closing and/or title insurance. These conditions impact legal, compliance, and investor requirements and will not be signed.
    • Please consult with your title underwriter as needed if you are unable to meet these requirements.

    A final important reminder is that Wells Fargo does not allow loan closing documents to be signed electronically or remotely notarized outside of limited RIN and RON LPOA processes implemented through specific, managed vendors.

    State-specific update: Florida reduced mortgage and/or intangible tax

    The State of Florida - Department of Revenue allows for reduced mortgage tax and/or reduced intangible tax on some refinance transactions. To qualify for the reduced tax, a specific Renewal, Extension and Modification Agreement (REMA) and process to modify the original lien is required.

    Wells Fargo policy and process does not support executing this REMA process for our refinance transactions, and therefore requires the Florida tax to be calculated on the entire loan amount and disclosed accordingly in our borrower CD.

    We have experienced some examples where settlement agents are attempting to apply the reduced tax to refinance transactions outside of the REMA process. This may be happening due to differing legal opinions on the Florida law, or for other reasons. In any case, this is not allowed on a Wells Fargo transaction. We appreciate your cooperation to adhere to our instructions on this matter for Florida refinance transactions.

    IRS Form 1099-NEC

    Wells Fargo is required to send Form 1099 to a business that is paid by Wells Fargo for services performed, or for known compensation paid to a business. For settlement agents who closed Wells Fargo loans, Wells Fargo wired loan proceeds to your business, and some of these loan proceeds paid for title and/or closing services performed.

    Form 1099-NEC is required when Wells Fargo is acting as a "middleman", making payments of income for services on behalf of someone - in this case, the borrower. This reporting is required because Wells Fargo directly provided payment to your business and has oversight or management of the payment, or has a significant economic interest in the payment being made. Please reference the Middleman Regulations under IRS Regulation Section 1.6041-1(e), "Payments made on behalf of another person".

    Applicable 1099-NEC statements for 2020 activity will be mailed on or before January 31, 2021. The Form 1099-NEC provided by Wells Fargo includes fees paid to your business for loan closing services provided during 2020. Wells Fargo referenced the final Closing Disclosure(s) from applicable transactions to determine the amount(s) paid to your business for these services. Reported income was aggregated by Tax ID Number for all Wells Fargo loans closed and funded in 2020. The 1099-NEC is issued using information contained in the W-9 that was provided to Wells Fargo for your business.

    Form 1099-NEC can be used as a supplemental document to your accounting books and records. Wells Fargo cannot provide tax advice, so please consult your tax advisor if you have questions. If you or your tax advisor require additional information, please send a written request to us at with a detailed description of the information being requested.

    Consumer financial protection notice

    Consumer financial protection laws and regulations may apply when you have direct or indirect contact with a consumer related to a financial product or service. The following information may be useful to you as a resource to identify the federal consumer financial laws and regulations that are applicable to the services you provide to Wells Fargo customers when you act as the settlement agent.

    This is not an all-inclusive list of laws and regulations that your business is subject to, so please consult with your compliance officer or legal advisor with any questions you may have. We appreciate the importance that you place on consumer protection for our mutual customers.



    Reference Information

    Americans with Disabilities Act, Title III

    ADA; Availability of programs, products and services

    28 CFR Part 36 Subpart C 36.303; 28 CFR Part 36 Subpart C 36.302

    Equal Credit Opportunity Act

    Fair Lending

    12 CFR 1002.4; 24 CFR 100, Subparts B-H

    Fair Credit Reporting Act/Fair and Accurate Credit Transactions Act

    Duties regarding detection, prevention and mitigation of Identity Theft, including indication of Fraud and/or Active Military Duty

    FCR 605A; 12 CFR 222.90 or 12 CFR 41.90; Section 615(e ); 15 U.S.C. 1681m(e )

    Financial Elder Abuse Reporting

    Elder Financial Abuse

    12 USC 3423(a)(2); 12 USC 3423(b)(1); 12 USC 3423(b)(2)(A)-(C )

    Real Estate Settlement Procedures Act

    Prohibition against Kickbacks and Unearned Fees and Required use of Title Company

    12 CFR 1024.14; 12 CFR 1024.16

    Privacy of Consumer Financial Information — Restrictions on Disclosing Non-Public Information Under GLBA

    Restrictions on Sharing, Receiving, or Reusing Information

    12 CFR 1016.11, CFTC Rules 160.11, Reg S-P 248.11, 12 CFR 1016.12, 12 CFTC Rules - 17 CFR 160.12 Reg S-P Rules - 17 CFR 248.12(d)

    Telephone Consumer Protection Act (Privacy)

    Fax Identifying Information

    47 C.F.R. § 68.318(d)

    Truth in Lending (Regulation Z)

    Disclosures - Consummation

    12 C.F.R. §1026.38; 12 C.F.R. §1026.27; 12 C.F.R. §1026.22; 12 C.F.R. §1026.14; 12 C.F.R. §1026.17 and 18; 12 C.F.R. §1026.19; 12 C.F.R. §1026.5 and 6; 12 C.F.R. §1026.4

    Truth in Lending (Regulation Z)

    Record Retention (Regulation Z)

    12 C.F.R. §1026.25

    Truth in Lending (Regulation Z)


    12 C.F.R. §1026.23; 12 C.F.R. §1026.15

    Unfair, Deceptive (or Abusive) Acts or Practices - Consumer Transactions

    PRICE: Appropriate Pricing

    16 C.F.R. §433; 16 C.F.R. §444; 15 U.S.C. §45(a) and 45(n); Dodd Frank Act 12 USC §5536; Dodd Frank Act 12 USC §5531

    Unfair, Deceptive (or Abusive) Acts or Practices - Consumer Transactions

    PLACE: Responsible Sales Methods & Appropriate Channels

    16 C.F.R. §433; 16 C.F.R. §444; 15 USC § 45(a) and 45(n); Dodd Frank Act 12 USC §5536; Dodd Frank Act 12 USC §5531

    Unfair, Deceptive (or Abusive) Acts or Practices - Consumer Transactions

    PROCESS: Responsible Servicing/Decision Making

    16 C.F.R. §433; 16 C.F.R. §444; 15 USC §45(a) and 45(n); Dodd Frank Act 12 USC §5536; Dodd Frank Act 12 USC §5531


    Thank you for your time to review this important information. Please share this with your staff and management teams. To request copies of any past newsletter editions, subscribe to future editions, or to provide suggestions, questions and comments please write to us at:

    We appreciate your partnership and the service you provide to our customers, and wish you a safe and successful year ahead.

    Wells Fargo & Company


  • 01/12/2021 5:07 PM | Scott Merritt (Administrator)

    Cyber threats are likely to increase and evolve throughout 2021, so start exercising your muscles and get started on your CYBER SECURITY NEW YEAR’S RESOLUTIONS before it’s too late!

    1.   Update Your Passwords. Passwords that are too obvious make it easy for hackers to access your personal data, which could result in blackmail or identity theft. 
    • Resist the urge to use the same password on numerous sites. 
    • Consider using a passphrase instead of a password – using letters, Capitalization and special characters.
    2.   Avoid Over Sharing. Facebook, Twitter, LinkedIn and Zoom are not always secure forums, so thinking before you post or go live is essential.
    • Enable privacy settings to restrict access to personal information.
    • Pay special attention to what is in the background in posts and videos
    3.   Take Extra Care with Emails and Texts.  Spoofing is one of the easiest ways fraudsters gain access to information.
    • Never click a link or open attachments in unsolicited emails and texts.
    • Verify emails and texts are legitimate by calling sender using verified phone number.
    4.   Avoid Public Wi-Fi.  Public Wi-Fi is a shared service and is not as secure as your home network. Avoid performing sensitive activities while on Public Wi-Fi (e.g., mobile banking).
    • Consider using VPN for remote work.
    • Consider using a separate Wi-Fi network for remote work.
    • Wi-Fi networks should be password protected.
    5.   Incident Response Plan.  Having a plan in place in case of a breach is essential.
    • Create a checklist with steps to take if a breach occurs. Please visit FLTA - Cyber Security and download our Rapid Response plan.
    • Create a “Call Tree” of contacts when a breach or emergency occurs. Test monthly or quarterly.
    • Document and preserve all information from breach.
    6.   Data protection and Systems.  Like a security system; invest in it up front and you will be more secure.
    • Dual control (no one should have complete authority of systems)
    • Two step authentications
    • Keep tokens (and passwords for same) in a safe place.
    • Have a secure backup system.
    • Invest in an IT expert that you can reach out to for reference.
    • Have system in place for retaining secure information.
    • Lock computers when not in use.

    Make sure you incorporate CYBER SECURITY into your daily workout in 2021 and stay one step ahead of cybercrime with the tips listed above!

    **The Cyber Security Committee meets on the first Wednesday of the month and is open to all members. Email Jena Daly if you would like to participate.**

  • 12/19/2020 11:14 AM | Scott Merritt (Administrator)

    In responds to the initial request of Senator Passidomo and with the approval of Senate President Simpson, The Office of the Program Policy Analysis and Government Accountability (OPPAGA) has published their study on the impact of redaction in the Official Records. A complete report follows the summary.

    A Review of Home Address Redaction Processes and Real Property Interests. 

    Report Summary

    • Florida has public record laws that apply to a variety of governmental documents, including those relevant to property transactions. While broad access to public records fulfills an important role, these laws can adversely affect some individuals due to their occupation or other status that puts them at increased risk of harm. As a result, s. 119.071(4)(d), Florida Statutes, allows some individuals, largely current or former government judiciary or law enforcement employees, to redact personal identifying information from public records. The spouses and children of most of these government personnel are also eligible for redaction, as are other groups such as members of the military and victims of certain crimes. The redaction ability of eligible individuals under s. 119.071(4)(d), Florida Statutes, including their spouses and their children, is applicable to property records throughout their entire lives with no requirement for renewal.

    • Florida’s 67 clerks of the circuit court and county comptrollers are responsible for recording official documents, including those related to property transactions. Clerks are also responsible for redacting certain information in these documents when requested by eligible individuals. Additionally, other governmental entities maintain documents with personal identifying information that qualifies for redaction. Eligible individuals must request redaction from each governmental entity that maintains personal identifying information. Clerks have similar processes for redacting information from property records; however, processes for verifying the redaction eligibility of individuals varies.

    • While overall redaction numbers are low, a 2019 law change expanded the definition of home address resulting in the ability for qualified individuals to redact legal descriptions of property from county official records. Key stakeholders identified several issues related to redaction, including those related to constructive notice, chain of title, potential for fraud, providing a false sense of safety, land surveying, and delays in real property transactions.

    • Several states have implemented programs to keep eligible individuals’ address information confidential while still granting limited access to property records. The Legislature may consider options to reconcile the goal of protecting individuals’ privacy with the need to protect the public interest in real property. These options include modifying an existing address confidentiality program to include personnel identified in s. 119.071(4)(d), Florida Statutes; requiring qualifying individuals to periodically renew redaction requests; requiring a notarized affidavit for redaction eligibility; and directing the clerks to redact information from internet indexes while making unredacted versions of documents available to the public for inspection and copying in their offices.

    Report PDF Link

  • 12/11/2020 10:41 AM | Scott Merritt (Administrator)

    Dear fellow members,

    With this Season’s Greeting, I would like to start by thanking every member of this Association as well as our Executive Director, Scott Merritt, and our Administrator, Jena Daly.  This year has not at all been what we expected for 2020, but we still have much to be thankful for this year.  And my thanks start and end with each of you.

    Though we have been apart for the better part of a year, we still found ways to stay connected and advance the interests of our industry.  Can you imagine what this year would be like if the FLTA had not already worked:

    • To enact remote online notarization legislation that became effective on January 1st of this year and then created the necessary education course to make it a reality for Florida Notaries? 
    • With the Office of Insurance Regulation to streamline the data call?
    • With the Department of Financial Services to clarify rules regarding third party charges and unlawful inducements?
    • To educate so many on the dangers of cyber criminals and wire fraud?

    Words cannot capture the immense pride and gratitude that I have for the leaders of this Association and professionals in our industry as so many have demonstrated incredible support for one another, our customers, our people in need, and the thousands of communities we serve.  As an industry and as an Association, we have been dedicated, incredible, and Essential.

    And I am so grateful that we were able to maintain a sense of family and community as we bonded together during our first-ever, Virtual Convention: The Roaring 20s – know the past, live in the present, and secure the future.  Our Convention and your engagement exceeded my expectations. 

    Resilience is often thought about in terms of simply getting through challenges, but the key part of resilience isn’t about bouncing back, it’s about bouncing forward.  It’s about using adversity as a catalyst to do something new, to get better, and become stronger.  Our Association was built to handle moments like this and I ask all of you to continue your engagement and contribute to the FLTA mission, to help increase our adaptability, diversity, and inclusion, and to be resilient together. 

    Speaking of doing something new, I am incredibly proud that our Board of Directors authorized a $20,000 donation to be split between five Florida area food banks with a call to action for our members to join us in helping those in dire need as a growing number of our neighbors and friends are going hungry.  Thank you, Lyndsay Hall Harrison, our Treasurer, for this terrific idea!  Our members were so motivated by this call to action that we have already collectively donated more than $55,000 and this is just the beginning.  We have added a specific line item for charitable giving into our 2021 Budget and will establish a Charitable Committee so that our Association can continue to make the biggest impact for members of our communities in need.

    I am very grateful for your continued involvement during these challenging times.  We are truly stronger together and my wish for you remains the same:  Have a healthy, safe, and joyous Holiday Season and may the Holiday Cheer get us all to next year with a renewed sense of peace and faith in the future!

    Len Prescott

    2020-2021 FLTA President

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