ALTA Releases Workbook for Third Pillar of Best Practices: Protecting NPI

October 3, 2013

ALTA has created a Best Practices Assessment Preparation Workbook that members can use to examine adoption of ALTA’s “Title Insurance and Settlement Company Best Practices” and measure if a company is prepared to undergo an assessment.

ALTA is providing a Workbook for each pillar of the Best Practices. The final Workbook released today is for pillar No. 3, which addresses protecting non-public personal information. ALTA also will publish a policy-building tool to help members develop their own written procedures.

Click here to access the Workbooks. You will need your ALTA login and password to access the document.

“We are hopeful that ALTA members find these Workbooks helpful in preparing for a Best Practices Assessment and also in the day-to-day running of your company,” said Michelle Korsmo, ALTA’s chief executive officer. “You can think of the Workbook as the Cliffs Notes to help title professionals prepare for the Assessment.”

The Workbooks consist of various tabs that include a cover page, an introduction letter, instructions, questionnaire, worksheet(s) and an action item report. In addition, the Workbook for pillar No. 3 includes a information security glossary, which provides a definition for many technology related terms.

The Workbook questionnaire tab includes a series of questions asking about a company’s business practices. Questions are broken out by each Best Practices pillar and designed to match up with the requirements of the Best Practices and the Assessment Procedures.

The questionnaire in the Workbook for the third pillar is broken into eight sections and includes 157 questions. Each question should be answered with either a “yes” or “no.” Some questions may require an explanation. In addition, the Workbook asks to indicate whether the practice is documented in a company’s written procedures and whether the company has a system for determining if employees follow the procedures.

“If completed electronically, the Workbook generates a useful report outlining what items your company may need to implement and add to your written procedures in order to pass an Assessment,” added Frank Pellegrini, ALTA’s president. “This action report is a great tool to help you figure out where your company stands in the Best Practices process.”

For Herschel Beard, who is the owner of Marshall County Abstract Co. in Oklahoma, the Workbook provides his operation an executable plan in reviewing its policies and procedures.

“As many title company owners and managers can attest, finding time to evaluate what Best Practices your company has implemented and documented can be challenging,” Beard said. “But the Workbook breaks it down in manageable chunks so if you spend a little time each day you can get a useful report of what you need to do and avoid business disruptions. If you’re waiting for a lender audit or assessment to get this done, you’ve waited too long.”

Meanwhile, the Workbook is beneficial for large companies as well, such as Orange Coast Title Company Family of Companies, which offers title insurance in 45 states and closing services in all 50 states.

“The Workbooks provide a solid blueprint on how to get through a lender assessment,” said Bill Burding, Orange Coast Title’s general counsel. “With lenders being held accountable for the actions of their service providers, this is a perfect time for our industry to shine. The title industry has long provided services that protect the integrity of the transaction, but this exercise helps in putting policies and procedures to paper, which is what lenders and regulators want and deserve.”

Instructions for Completing the Workbook

Below are instructions on completing the Workbook. ALTA also has created a tutorial video to help you complete the Workbook.

Open the Workbook and click the Questionnaire tab. This tab contains the Workbook questions that you will need to answer.

In columns D and E, place an “X” in the appropriate box for a “yes” or “no” response. Some questions may require a description or comment in addition to the “yes” or “no” answer.

When answering column F, determine whether the control specified in the question is formally documented in your organization. If so, leave this column blank. If it is not documented, place an “X” in this column.

Likewise, when answering column G, determine if your company possesses any documentation or other evidence to prove that you follow the written procedures identified previously. If the answer is “yes,” leave this column blank. If you do not have documentation or other evidence for this procedure, place an “X” in this column.

If a question does not apply to your company, enter N/A and include a reason why the question does not apply in the “Descriptions/Comments” box. Some questions require a narrative response to be entered in the Descriptions/Comments box. These questions will have the responses shaded in grey.

Once you have completed the questions, click on the action items report tab. This report will compile all questions for which you provided a “no” response. These are the controls and procedures that your company will need to implement prior to undergoing an Assessment.

Contact ALTA at 202-296-3671 or [email protected].