On September 17th, the National Association of Independent Land Title Agents (NAILTA) sent out the NAILTA Member Update to all it’s members concerning CFPB Bulletin 2012-03. This Bulletin was issued by the Consumer Financial Protection Bureau (CFPB) in an attempt to address Dodd-Frank Act compliance for supervised banks and nonbanks. While initially directed at banks and nonbanks (i.e. credit unions, etc.), the bulletin has since been used as the grounds to spawn third party vetting companies, like Secure Settlements, Inc., that seek to impede the use of independent title agents by supervised banks and nonbanks.
A copy of the CFPB Service Provider Bulletin 2012-03 can be found by clicking on the highlighted link. NAILTA’s Policy and Legal Affairs Committee has authored the enclosed white paper on the Bulletin and the propagation of third party vetting companies like Secure Settlements. A copy of the NAILTA white paper can be found by clicking here.
On Tuesday, September 25, 2012 at 1:30pm ET, NAILTA’s Policy and Legal Affairs Committee held a members-only teleconference to discuss plans for meeting with the author of the CFPB Bulletin 2012-03.
The Ohio Association of Independent Title Agents (OAITA) has since sent the enclosed letter to Ohio Department of Insurance Director and Lt. Governor Mary Taylor concerning third party vetting companies and potential violations of state and federal law as enumerated in the correspondence.