CFPB Responses & AOL Memo
Hello Members!
Only 3 weeks until the kickoff of Gator football! While I do not attend the games in person (too hot; too crowded), I do enjoy the hype that comes along with it and the opportunity to watch college football in the comfort of my own home with friends and family around. Hope whatever team you support has a good year (but I will be rooting for the Orange and Blue).
Two good things to share with you today.
ALTA/FLTA responses to CFPB RFI. Don't you love the string of acronyms? Ha. Let me translate. Back in May, the Consumer Financial Protection Bureau issued a Request for Information Regarding Fees Imposed in Residential Mortgage Transactions. Comments were solicited from a wide variety of groups and individuals with an interest in this topic and there were quite a few comments provided! But of particular interest to Fund Members are the responses filed by the American Land Title Association and the Florida Land Title Association. I encourage you to read them, despite their length. It's a good refresher on our industry and how we do what we do. Additionally, the ALTA response points out several areas in which our services and our fees are misunderstood. Here is a link to the ALTA letter. https://www.thefund.com/TheFund/media/PDFs/GeneralCounsel/ALTA-CFPB-Mortgage-Closing-Costs-RFI-August-2024-FINAL.pdf
DO YOU RECOGNIZE THE CHART AT THE END OF THE ALTA LETTER? The Fund's contribution to this very important letter is something of which we can all be proud! And here's a link to the FLTA letter. https://www.thefund.com/TheFund/media/PDFs/GeneralCounsel/2024-08-FINAL-FLTA-RESPONSE-TO-CFPB-REQUEST-FOR-INFORMATION-CFPB-2024-0021.pdf
Attorney Opinion Letters. Many of you have contacted me or other folks at The Fund about various vendors promoting the use of AOLs and perhaps even soliciting your services in connection with a transaction in which an AOL is requested (and not a title insurance policy). There are a lot of things for you to consider in connection with these products and what you are being asked to do. You need to read the requirements very carefully. I am not going to get into details about any particular vendor's program, but we have put together the attached memo, which I hope will provide you with some guidance. And if you have any questions, feel free to contact me at mmurphy@thefund.com (do NOT reply to this email; it takes much longer to get to me). https://www.thefund.com/TheFund/media/PDFs/GeneralCounsel/Fund-Memorandum-AOLs-Aug-2024.pdf
I think that's enough for this week, don't you?
Let me know how we can help you.
Melissa Jay Murphy
Executive Vice President, Chief Legal Officer,
and General Counsel
08/12/2024