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Best Practices

Tips on Enhancing Consumer Care and Resolving Customer Complaints

July 17, 2014

With financial institutions being held responsible for actions of third-party service providers, your lending clients will want to know how quickly you respond to consumer complaints and will require settlement providers to track these efforts.

During an ALTA Title Topics webinar, Terrie Miller of H.B. Wilkinson Title Company and Alison Gareffa of Old Republic National Title Insurance Company provided tips on how to develop procedures for handling consumer complaints. Resolving consumer complaints is the seventh pillar of ALTA’s “Title Insurance and Settlement Company Best Practices,” which says a process for receiving and addressing consumer complaints helps ensure reported instances of poor service or non-compliance do not go undiscovered.

This is important as the Consumer Financial Protection Bureau (CFPB) is focused on enhancing the consumer experience and expects companies to have a process in place to handle and resolve complaints. The CFPB issued a bulletin in June regarding responsible business conduct and provides insight into the Bureau’s mission and further supports the importance of resolving consumer complaints. The bulletin encourages “activity that has concrete and substantial benefits for consumers and contributes significantly to the success of the Bureau’s mission.”

“How each of our companies handles Best Practice No. 7 will likely be important to the CFPB,” Gareffa said. “One thing is clear we can all use tools such as resolving consumer complaints to improve upon what we do. The bottom line is the best defense is a good offense.”

What's a Complaint?

The first step is building a consumer-complaint resolution process is defining what constitutes a complaint. Rate-related complaints can be broken into two buckets, according to Gareffa. In states where there are no set rates, complaints could be made through the DOI or the agency. In many states, the DOI will refer the consumer back to the title company. Each state DOI has its only procedures for handling complaints. In states where rates are filed, where there’s a rating bureau or where rates are promulgated, complaints would go directly to the department of insurance.

Complaints that are customer service in nature—such as an error that could be a claim or an error in the closing process—need to be handled by the title company. Protocol of the state where the company operates would need to be followed. Having standard procedures for logging and resolving consumer complaints help ensure that consumers provide the company with sufficient information to understand the nature and scope of the complaint.

“When a consumer is making a complaint, it’s always best to note it in the file so if something comes back later you can prove you had conversation,” Miller said. “Put as much as possible in an electronic file.”

Interacting With Consumers

It’s important to make every effort to give the consumer a positive experience. When customers give feedback that isn’t positive, Miller said you should be ready to listen and be apologetic that they are upset and advise you’ll investigate further.

“Training employees to keep calm when conversing with an irate consumer is important,” Miller said. “Remember to talk softly and let the consumer finish what they are saying. Repeat to them what they said. At the end of the conversation, you want them to go away happy.”

Title companies should also train their employees to try and not resolve complaints during the conversation. The objective should be to gather as much information as possible from the consumer.

“Resolving something on the phone can often lead to incorrect information provided to consumer,” Miller said. “After collecting the information, let the consumer know what steps you will take to resolve the issue and reassure them that you’ll follow up.”

Point Person

Keeping consumers updated throughout the process is important. Companies should then determine the method of communication when a resolution is reached. This can be by phone, email or letter.

Designating a single point of contact to handle all consumer complaints is another important part of the process. Miller said it should be someone who has the authority to make decisions.

“Passing them up the chain where the consumer may first talk to the receptionist and then the title processor only aggravates the consumer,” she said. “Think about when you call your credit card company and you have to go through many automated versions until you get to a human. Be cognizant of that when speaking with the consumer.”

A back-up person to the main contact should be designated to help ensure consumers can speak to a person when calling with an issue.

Log Complaints, Track Progress

Miller encourages companies to enter all complaints into the log as this will help provide guidance on how you operate internally. She suggested companies have management periodically review, date and sign-off on the log.

“Keeping a regular log of problems provides a great company-wide evaluation in how you are servicing customers,” she added.

Gareffa encouraged companies to develop a standard consumer complaint intake form that can be used for all forms of complaints, whether they come by email, letter or phone. This will help in documentation and tracking of complaints. Everything should then be transferred to the standard complaint form. According to Gareffa, the form should include information that connects the complaint to a specific transaction, including consumer contact information, property address and transaction information (agent file number and policy number).

Here’s a list of items that could be included in the complaint log:

  • Consumer name
  • Brief description
  • Date received and to whom assigned
  • Date of last contact with consumer
  • Date of last activity or updated information
  • Status (i.e. Pending, Action Required, Resolved)
  • Date resolved and description of resolution
Title companies should make it as easy as possible for consumers to contact them. Information on the company website and closing packages should be updated.

Companies may also want to consider making the consumer complaint log a form-fillable PDF or store the document on a shared network drive.

“If you are a paperless company or have multiple offices this makes the log available to all offices,” Miller said. “If will become a live document and can be updated easily. If a point person is out of the office, then the secondary person has something to review and see progress on a complaint.”


Many underwriters have developed templates to help agents develop their own consumer complaint resolution procedures. However, it’s important that each company modify the samples to meet market requirements and contract requirements.

As part of the Best Practices Framework, ALTA is developing Assessment Readiness Guides to help members determine if they are prepared to undergo an assessment to determine compliance with ALTA’s “Title Insurance and Settlement Company Best Practices.”

Click here for more information on ALTA’s Best Practices.

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