Due Diligence and Ongoing Monitoring

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  • 1.  Title Companies

    This message was posted by a user wishing to remain anonymous
    Posted 09-21-2022 12:56 PM
    This message was posted by a user wishing to remain anonymous

    When it comes to title companies, how do you assess, measure, monitor and manage risk? 
    Can title companies be "carved out"?

    Thanks!


  • 2.  RE: Title Companies

    Posted 09-22-2022 09:03 AM
    For your consideration:

    The customer and the seller (if applicable) select the title provider. As a lender, we are required to provide a list of available providers in the area, as part of TRID. The disclosure indicates this is not an endorsement of or recommendation of the Title provider.

    Therefore as a lender, my perspective is the title company is not a vendor under the control of the bank and can reasonable be carved out of the TPRM inventory/program.