Welcome to ALTA Best Practices Readiness Tool

Agency name:
Agency contact:
Email:
Phone Number:
Address:
Number of locations:
Average number of transactions per month:
Primary underwriter:
Secondary underwriter:

Pillar 1: Licensing


1. Policies and Procedures:
a. Are you maintaining up to date licensing?
2. Implementation:
a. Can you provide readily accessible copies of all applicable individual and company licenses, state regulatory agency status, bar association status, and/or business registrations along with your ALTA Policy Forms License?
Questions or comments on Pillar 1:

Pillar 2: Escrow Accounting Procedures


1. Policies and Procedures: a. Do you have policies and procedures that address each of the ALTA Best Practices related to controls for escrow or trust accounts?
2. Implementation:
a. Do signers, wire initiators, and approvers 1) appear on the active employee listing, 2) have 5-year background checks at time of employment or within last 3 years, and 3) have documentation indicating they have been trained on the management of escrow funds?
b. Is a two-way reconciliation performed daily on all active trust accounts?
c. Is a three-way reconciliation performed monthly on all active trust accounts?
d. Are duties appropriately segregated so signers, wire initiators, and approvers are not performing the reconciliations?
e. Does management review and sign off on three-way reconciliations?
f. If available, have you implemented Positive Pay or Reverse Positive Pay?
Questions or comments on Pillar 2:

Pillar 3: Privacy and Information Security


1. Policies and Procedures: a. Do you have policies and procedures that address each of the ALTA Best Practices related to your agency's privacy and information security program that are signed annually by management?
2. Implementation:
a. Do all employees with access to NPI 1) complete training on the agency’s information security program/policy, 2) complete an acceptable use of information technology assets agreement, 3) complete training on the Company's Privacy Policy, and 4) complete background checks?
b. Do you have an NPI Security Risk Assessment that includes: 1) risk ranking of information systems, 2) locations, systems, and methods for storing, processing, transmitting, and disposing of customer information, and 3) listing of potential internal and external threats to customer information?
c. Do you regularly test all key controls related to Pillar 3 to include 1) systems and procedures that have been prepared to protect NPI, 2) system backup and business resumption, and 3) removing termed employees?
d. Are duties segregated such that administrative access rights to systems containing NPI are not assigned to personnel performing business transactions within the system?
e. Do you follow your policies related to the security of removable media?
f. Can you demonstrate that you encrypt electronically transmitted or stored NPI?
g. Do you document (either internally or through a third party) 1) an intrusion and attack report, 2) a user access report, 3) the use of logical access controls (passwords), and 4) that changes to your technology and business functions are consistent with your security program?
h. Do your physical locations follow a clean desk policy and control access to areas containing NPI?
i. Have you documented due diligence on your third-party vendors that have access to NPI?
i. Do you provide your Privacy Policy to your customers?
k. Do you post your Privacy Policy on your website?
l. Do you maintain documentation on the disposal of documents and electronic media?
Questions or comments on Pillar 3:

Pillar 4: Settlement Procedures


1. Policies and Procedures:
a. Do you have policies and procedures that address each of the ALTA Best Practices regarding compliance with federal and state consumer financial laws as applicable to the settlement process?
2. Implementation:
a. Do you document that you submit, or ship, documents for recording within two business days of the later of 1) date of Settlement or 2) receipt by your agency if the Settlement is not performed by your agency?
b. Are rejected recordings addressed within two business days of the receipt of the rejected documents?
c. Are current filed or promulgated rates, endorsements, and /or rates established by your underwriter used?
d. Are established non-title insurance rates used?
e. Are refunds issued upon discovery where an overpayment occurred?
e. Do you have a standard rate sheet?
g. Do you perform a quality review after the settlement?
Questions or comments on Pillar 4:

Pillar 5: Title Policy Production and Delivery


1. Policies and Procedures:
a. Do you have policies and procedures that address each of the ALTA Best Practices related to title policy production, delivery, reporting and premium remittance?
2. Implementation:
a. Are you documenting that title insurance policies are issued and delivered to customers within 30 days of Settlement or within 30 days of the terms and conditions of the title insurance commitment having been satisfied?
b. Do you document that you remit the correct portion of the premium to the underwriter by the last day of the month following the month in which the insured transaction was settled or according to the terms in your underwriter agreement?
Questions or comments on Pillar 5:

Pillar 6: Professional Liability Insurance Coverage


1. Policies and Procedures:
a. Do you maintain appropriate professional liability and fidelity insurance?
2. Implementation:
a. Do you have written confirmation from your underwriter regarding the acceptability of your professional liability and errors and omissions insurance?
b. Do you have sufficient coverage as required by your state? If your state does not have a minimum coverage requirement, please select “Yes.”
Questions or comments on Pillar 6:

Pillar 7: Consumer Complaints


1. Policies and Procedures:
a. Do you have policies and procedures that address each of the ALTA Best Practices related to resolving consumer complaints?
2. Implementation:
a. Do you have a method for tracking and resolving consumer complaints that connects the complaint to a specific transaction and provides information to understand the nature and scope of the complaint?
b. Is there a process to forward the complaint to the appropriate person and/or department that has been established to address consumer complaints?
c. Is there a log maintained of consumer complaints that includes whether resolution is necessary and how the complaint was resolved?
Questions or comments on Pillar 7: