DFS & CFBP Guidance Available but Not Candy Hearts

Dear Members,

I have disappointing news. I recently learned that the company that bought Necco will not be able to manufacture the heart shaped candies with inspiring messages that I personally have looked forward to every Valentine's Day. I have relied on those little bits of sugar to get me through the long February days with not only a sugar buzz but with a re-adjustment of my focus on what is important. "Be Mine." "Email me." So inspiring….. I think there are alternatives but there is no replacement for the original brand! There is hope, however, because I think they will be able to bring the Sweetheart Conversation Hearts back in 2020.

Updated guidance from DFS.

The Department of Financial Services (DFS) has updated their guidance to title agents and very recently updated guidance on third party fees that title agents incur in connection with the closing of a transaction. Here is a link to the guidance page. https://www.myfloridacfo.com/division/agents/compliance/TitleAgents.htm.
You can click on the various topics and get the full guidance. Look at the one on third party fees. There is some new stuff in there. It raised several questions for me and I am sure you will have some, too. We are not alone. I am working with other people in the industry (through FLTA) to try and get this whole issue to a better place. I know that sounds vague but keep the faith. We are working on it.

CFPB FAQs!

No, the above is not a misprint. CFPB has issued some guidance. Holy Moly! You might be interested in reviewing these new FAQs. Here is a link to them. https://www.thefund.com/information-center/pdf/cfpb/tila-respa-integrated-disclosure-faqs.aspx. Of note is some guidance on when a new 3-day waiting period is not required when a revised Closing Disclosure is issued - best answer is "it depends" but the FAQ provides helpful information.

Weekly Cyber Fraud Update

"Only the paranoid survive." I heard this the other day on a discussion of cyber fraud in our industry. Kind of sums up the best philosophy for avoiding a problem. In the meantime, you could sign up for our latest Fund Town Hall dealing with this issue. Insuring against Mortgage Payoff Fraud, Business Email Compromise Fraud & Other Social Engineering Frauds will be hosted by Michael Rothman, Fund Legal Education Manager, at noon on February 19, 2019 (EST). Please check The Fund's website for more details.

ALTA licensing fees.

Many of you have received a letter from the American Land Title Association (ALTA) asking you to remit an annual license fee for the use of ALTA title insurance forms. This is a legitimate letter and a legitimate request. Please respond quickly by sending in your fee. Better yet, consider joining ALTA. I have learned so much about this organization and feel that it is an invaluable resource for the industry. I wish I had known this while in practice so that I could have gotten involved and supported it as a member. The license fee is $195. A membership for most title agencies/law firms is $460, which provides you with access to a whole host of resources. Go to www.alta.org for more information. Or you can reach out to me!

Let me know how we can help you.

Melissa Jay Murphy
Executive Vice President, Chief Legal Officer,
General Counsel and Secretary