joseph l. petrelli, acas, maaa, fca president, demotech, inc. arkansas land title association

Joseph L. Petrelli, ACAS, MAAA, FCAPresident, Demotech, Inc.

Arkansas Land Title Association

In 2006 Demotech, Inc. published What We Have Here is A Failure to Communicate. Our white paper described the critical coverage and loss adjustment expense differences distinguishing Property and Casualty insurance from Title insurance. Furthermore, Demotech, Inc. described how financial reporting requirements failed to capture and summarize those differences.

This presentation provides additional insight and detail on the failing of current, or proposed, statistical and financial plans applicable to Title insurance. The opinion and perspective presented are those of Demotech, Inc. and do not necessarily represent the opinions or perspectives of our clients, or the Title underwriters we review and rate.

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The National Association of Insurance Commissioners’ Title Agent Statistical Data Plan

The National Association of Insurance Commissioners (NAIC) has adopted the Title Agent Statistical Data Plan (“NAIC Plan”) to collect financial data from title agents nationwide. The NAIC has recommended that each state implement this NAIC Plan to assist regulators in the oversight of the title insurance industry.

Part I of this section of the presentation tracks the origins and development of the NAIC Plan, and explores the purpose of the NAIC Plan. Part II provides details on the actual data reporting requirements, including a line by line analysis of the NAIC Plan and overview of the NAIC’s recommended standards for implementation. In Part III, we summarize the NAIC Plan’s Implementation guidelines.

NAIC, Title Agent Statistical Data Plan Implementation Guideline, 2011. (“Implementation Guideline”)

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Review of the NAIC and the REGULATION of INSURANCE

ORIGINS of the TITLE INSURANCE AGENT STATISTICAL REPORT

DEVELOPMENT of the NAIC PLAN

PURPOSE of the NAIC PLAN

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Insurance industry is regulated by the states National Association of Insurance Commissioners is a collective body Standard-setting, regulatory support organization Created and governed by the chief insurance regulators of the 50 states Started in 1871 to coordinate the regulation of insurers operating in

multiple states The NAIC establishes standards and best-practices for the insurance

industry’s regulators as well as insurers and other regulated entities

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http://www.naic.org/index-about.htm





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2007 Report from U.S. Government Accountability Office (GAO) to U.S. House Committee on Financial Services: Actions Needed to Improve Oversight of the Title Industry and Better Protect Consumers. (GAO-07-401)1

Highlights from report: Large insurers use local/regional title agents to conduct their business GAO thought understanding relationship between costs and amounts consumers

pay could help regulators improve their ability to protect consumers GAO recommended that state regulators take action to:

Improve consumers’ ability to shop for title insurance; AND Improve oversight of title agents

GAO recommended that regulators collect data on title agents’ operations NAIC listened to GAO recommendations and formed a task force to evaluate

the viability of a nationwide data call2

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Title Insurance Issues Working Group (TIIWG)/Title Insurance Task Force Sub-group of the P&C Committee of the NAIC Mission was to study issues related to title insurers and title insurance

producers 2008--TIIWG decided a NAIC Plan for title insurers should attempt to

measure, state by state: Profitability of title industry Competitiveness of title industry Reasonableness of rates and charges

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NAIC, Title Insurance (C) Task Force. Conference Call, Sept. 1, 2011. Project History: Title Agent Statistical Data Plan Implementation Guideline. (“Project History”)

2009—P&C Committee charged TIIWG with completing study on the ability to develop and implement a system to collect premium and expense data

TIIWG concluded that it could assist states in developing a data call plan TIIWG became the Title Insurance Task Force and appointed the Title

Statistical Plan Working Group to develop a nationwide statistical plan

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NAIC, Title Insurance (C) Task Force. Conference Call, Sept. 1, 2011. Project History: Title Agent Statistical Data Plan Implementation Guideline. (“Project History”)

Title Statistical Plan Working Group (TSPWG) Appointed by the Title Insurance Task Force to develop a nationwide

statistical plan and implementation strategies to assist states in collecting data3

TSPWG, with input from The American Land Title Association (ALTA), insurers, title agents, and software vendors, developed Title Insurance Agent Statistical Report (“NAIC Plan”).

NAIC Plan was fully adopted by NAIC in Fall 20104

TSPWG drafted guideline to assist states in implementing the NAIC Plan Title Agent Statistical Data Plan Implementation Guideline was adopted

by NAIC in Fall 2011.5

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Review of the NAIC and the REGULATION of INSURANCEORIGINS of the TITLE INSURANCE AGENT STATISTICAL REPORTDEVELOPMENT of the NAIC PLANPURPOSE of the NAIC PLAN

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“The purpose of the [NAIC plan] is to give information that is more useful to state regulators about the business of title insurance at the agency level.”*

NAIC recognized that in most jurisdictions performance of the title insurance business is based on the title agent, not the title underwriter

Annual financial report submitted by title underwriters includes information regarding premiums and losses, but does not include information about the title insurance business that is experienced only on the agent level

Regulators lack valuable information and have an incomplete picture of the title insurance business

NAIC proposes that jurisdictions need to obtain data from agents The purpose of the NAIC’s NAIC Plan is to collect information from title

agents, particularly regarding their actual operating costs and their losses

NAIC, Title Agent Statistical Data Plan Implementation Guideline, 2011. (“Implementation Guideline”)

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NAIC PLAN - OVERVIEW

NAIC PLAN - DETAILS

TITLE AGENT STATISTICAL DATA PLAN IMPLEMENTATION GUIDELINE

GOING FORWARD - WHAT WILL THE STATES DO?

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NAIC undertook to design statistical data reporting plan to collect data in five categories: General information and agency information Risk assumption Income Expenses Loss and loss mitigation

Goal of plan is to collect enough data to help regulators while not overburdening title agents

Instructions for: Single State Agent Multi-State Agent Attorney Agent Underwriter Direct

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NAIC PLAN - DETAILS



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A full copy of the Title Agent Statistical Stat Plan can be found at: www.naic.org/documents/committees_c_title_stat_plan_final.xls

Line # Line Description Single State Agent Multi-State Agent Attorney Agent Underwriter Direct

General Information

1 Calendar year reporting

Enter the four-digit calendar year for which you are reporting (e.g.,

reporting in 2012 for 2011, enter 2011)







2 State reporting for

Enter the two-letter state abbreviation of the state

for which you are reporting (multi-state

agencies should complete a separate report for each state, as required by other

states)


for which you are reporting (multi-state agencies

should complete a separate report for each

state, as required by other states)









3Agent/Agency/Firm

NameInsert Firm name or

individual agent's nameInsert Firm name or

individual agent's nameInsert Firm name or

individual agent's name Insert Firm Name

a) d/b/a (if applicable)If applicable, provide d/b/a

name for agencyIf applicable, provide d/b/a

name for agencyIf applicable, provide d/b/a

name for agency N/A

4

Federal tax ID/SSN (for Underwriter direct

operations: use NAIC Company Code)

Enter Federal Tax ID (or SSN for individual)



Enter reporting entity's NAIC Company Code

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Line # Line Description Single State Agent Multi-State Agent Attorney Agent Underwriter Direct

Parent Company EIN (if applicable) (for

Underwriter Direct Operations: use NAIC

Group Code)

If agency revenue is reported for taxes through a parent or other affiliate, enter such organization's EIN; otherwise indicate

"N/A)


"N/A)


"N/A)

Enter reporting entity's NAIC Group Code

5License number (for this

state)

Enter agency's license number in the state for

which you are reporting (if applicable)





Enter underwriter's license number in the state for which you are reporting

6 Address

Enter the complete address for the agency's

main office.


main office in the state for which you are reporting. If agency does not maintain an office in the state for which you are reporting,

enter the firm's main office address.


main office.

Enter the complete address for the direct

operation's main office in the state for which you are

reporting. If the direct operation does not

maintain an office in the state for which you are

reporting, enter the operation's main office

address.

7 Contact person

Enter First, Middle Initial and Last name of person

responsible for completing this report







Line # Line Description

General Information

1 Calendar year reporting2 State reporting for3 Agent/Agency/Firm Name a) d/b/a (if applicable)4 Federal tax ID/SSN (for Underwriter direct operations: use NAIC Company Code)

Parent Company EIN (if applicable) (for Underwriter Direct Operations: use NAIC Group Code)5 License number (for this state)6 Address7 Contact person8 Contact phone9 Contact e-mail

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Agency Information

10 Independent

11 Affiliated (owned by underwriter)

12 Underwriter direct

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Is reporting agent an Affiliated Business Arrangement (affiliated with real estate brokerage, mortgage company, etc.)? (Y)es/(N)o. If Yes, List affiliated business names on Appendix A

14 Agency/Branch Type:

Title & closing (full service)

Title only

Closing only

Attorney title

15State of domicile/residence of Reporting Entity/Person

16Number of states in which Reporting Entity operates (list all states on Appendix A)

17How long has agency been performing business in this state?

0-5 years 5-10 years 10-15 years Over 15 years

18Percentage of business for this state (by premium)

a) Percentage of law firm revenue

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Number of underwriter appointments, contracts, or agreements. (List underwriters on Appendix A)

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20 No. of employees (total FTE - as of last date of reporting period) a) No. of FTE on March 31 (end of Q1) b) No. of FTE on June 30 (end of Q2) c) No. of FTE on September 30 (end of Q3)

21 No. of unallocated FTE, as of last date of reporting period (December 31)22 Licensed employees a) No. of licensed FTE on March 31 (end of Q1) b) No. of licensed FTE on June 30 (end of Q2) c) No. of licensed FTE on September 30 (end of Q3)

23 No. of licensed, unallocated FTE, as of last date of reporting period (December 31)

List licensed employees (both allocated and unallocated employees) accounted for in Lines 21(a), (b), (c), and (d) on Appendix A

24 Unlicensed employees a) No. of unlicensed FTE on March 31 (end of Q1) b) No. of unlicensed FTE on June 30 (end of Q2) c) No. of unlicensed FTE on September 30 (end of Q3)

25 No. of unlicensed, unallocated FTE, as of last date of reporting period (December 31)

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Risk Assumption

26 Open Title Orders27 Completed Title Orders in Which Policy Was Issued28 Total number of policies issued in reporting period

a) Residential Policiesb) Non-residential Policies

29 a) Number of searches billed to 3rd partiesb) Number of searches purchased from 3rd parties

30 Number of non-insurance title products produced

31a) Total settlement/escrow/closing transactions conductedb) Number of line 28 that were sale/purchase settlement/escrow/closing transactions

32Number of settlement/escrow/closing transactions conducted in which a title policy was not issued

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Income

33 Premium written34 Premium remitted to underwriters35 Settlement/closing/escrow income36 Title examination income37 Abstract/search income38 Income from cancelled orders39 Investment income40 All other income

41 Total income

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Expenses

42 Employee compensation43 a) Contract labor (1099) b) Temporary labor (non-1099)

44 Payroll taxes45 Employee Benefits46 Rent, utilities, and repair47 Title plant maintenance/subscription expenses48 Abstract/search expenditures49 Computer/software a) Depreciation (if applicable)

50 Business insurance

51 Business legal52 Accounting53 Licenses, taxes, and fees54 Marketing/sales55 Travel and lodging56 Employee education57 Bank charges58 Charge offs59 E&O insurance premiums60 Fidelity/Surety bond premiums61 Miscellaneous expense

62 Total business expenses

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Loss, Loss Mitigation, and Underwriting Expenses

63Title losses paid and not reimbursed by underwriter or included in underwriter loss reserves

64 a)Title Loss Files Openedb) Title Loss Files Paidc) Reimbursements paid to underwriter for title losses

65 Closing/Escrow lossesa) Number of Closing/Escrow Losses resulting from escrow shortagesb) Total amount of funded shortages

66 Abstract/search losses (from abstracts/searches sold)67 Title loss-related and Closing/Escrow loss-related legal expenses68 Deductibles paid69 Total loss expenses70 Total expenses71 Net income before taxes72 Federal income tax incurred73 Net income

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Demotech’s note: Loss mitigation efforts are not captured. We suggested that, at a minimum, Schedule A and B counts be reported.


NAIC PLAN - DETAILS



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Title Statistical Plan Working Group issued an Implementation Guideline for the new Statistical Data Plan to assist state regulators with implementing the NAIC Plan

Part A. Introduction

Outlines the background and purpose of the NAIC Plan and provides general information regarding the NAIC Plan

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Part B. Mechanism for Reporting and Collection of Data/Implementation Data required has not been previously reported, but should be readily

available to title agents Task Force recommends that regulators provide as much notice as

possible before implementing the NAIC Plan so agents may adapt their systems to collect the required data

Task Force recommends annual reporting date of June 1 for previous year’s data

Recommend that regulators establish web-based reporting system

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Part C. Confidentiality of Data Task Force recommends that regulators keep individual responses on the

NAIC Plan confidential, but regulators should be allowed to share/publish aggregate data

Part D. Uses of Data Regulators should be careful if they intend to use NAIC Plan to set rates

or analyze justifications of rates and fees because NAIC Plan does not capture the entire agent experience

Task Force recognizes that regulators may use data to set rates

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Other uses of the data include: Fulfillment of GAO recommendations of increased title agent data

collection Comparison of relationships of costs to title agents and prices

consumers pay Quantitative analysis of differences between title insurance and other

lines of insurance Comparison of FTEs in agencies vs. total licensees in a jurisdiction Agent premium experience Market share analysis Marketing expense ratios (compared to market share) Premium vs. agency claims loss experience Agent experience by locality Development of market conduct base line market analyses

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Part E. Insurance Department Outreach Efforts Task force recommends that regulators engage in outreach and training

initiatives Suggest contacting state and national title associations, title insurance

data collection and consulting firms, title insurance underwriters’ state offices, state departments of insurance, and NAIC

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Part F. Suggested Statute Language Title Agent Statistical Data Plan.

1) Every title agency doing business in this state, on or before the last day of May in each year, shall submit to the commissioner a report, signed and certified by an owner, officer, partner, or director of the agency, of the specific information listed in the NAIC Title Insurance Agent Statistical Data Plan.

2) Information relating to the individual agencies filed with the commissioner under subsection (1) shall be kept confidential and not subject to public disclosure. However, nothing in this subsection (2) shall prohibit the commissioner from publishing data collected in an aggregate form, so as not to identify individual agencies’ data, or from sharing particular agency data with other state, federal and international regulatory agencies, with the National Association of Insurance Commissioners, its affiliates or subsidiaries, and with state, federal, and international law enforcement authorities, provided that the recipient agrees to maintain the confidentiality and privileged status of the information.

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Part F. Suggested Statute Language3) The commissioner may establish rules, including rules providing statistical

plans, for use by all title insurers and title insurance agents in the collection and reporting of demographic, revenue, expense and loss experience data in such form and detail as is necessary to aid him or her in the evaluation of the title insurance industry at the agency level.

Drafting Note: States that require the data to be submitted electronically should establish a method of electronic signature verification that is acceptable to the commissioner.

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Part G. Suggested Regulation on Reporting RequirementsDrafting note: This is not a model regulation, but a suggested regulation/best practice

for any necessary rules that may need to be promulgated for the implementation of the NAIC plan. When drafting regulations, take into account local statutes, practices, and customs and modify this regulation accordingly.

Section 1. Statement of PurposeThis regulation is intended to provide standards and direction for the collection and

reporting of title agent data in accordance with the NAIC’s Title Agent Statistical Data Plan. The regulation specifies the data required, due dates and time periods for collection and submission of data, methods of submission, and addresses the confidentiality of the data submitted.

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Section 2. Statutory AuthorityThis regulation is issued based upon the authority granted the commissioner under (cite any enabling legislation and state law corresponding to market analysis, market regulation, and/or title insurance regulation).

Section 3. Applicability and ScopeUnder this regulation, all operating title insurance agencies and underwriter direct operations are required to provide yearly reports of their policy issuance, business income and expense, and loss experience (excluding losses forwarded to or paid by an underwriter). Agencies include independent title agencies, affiliated business arrangement (AfBA) title agencies, attorney firms/title agencies, and underwriter direct operations.Drafting note: Types of entities may vary by state

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Section 4. Definitions1.Affiliated Business Arrangement (AfBA) – an arrangement in which a settlement producer, such as a real estate broker, developer, mortgage loan originator, or bank, or any other individual or entity that is in a position, directly or indirectly, to refer settlement business to a title entity, also maintains a direct or beneficial ownership interest in that title entity.2.Affiliated title agency – a title agency that is owned, either wholly or in part, by a title insurance company/underwriter, but does not operate as an underwriter direct agency.3.Attorney firm/title agency – a title agency that is owned and operated by an attorney or law firm.4.Independent title agency – a title agency that is not part of an ownership arrangement with a real estate settlement producer, or with a title insurance company/underwriter.

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Section 4. Definitions (cont.)

Drafting note: Individual states may have different definitions for some of the above items, or may have more or fewer definitions to include. In addition, definitions under Real Estate Settlement Procedures Act (RESPA) may vary from those listed above. States should update, add or delete definitions, as well as add relevant statutory citations as necessary.

Section 5. Data Required

Incorporate reference to NAIC plan here, rather than including the actual plan (to accommodate for future amendments to plan).

Section 6. Due Dates/Time Periods for Collection

All reporting entities are required to submit the data referenced in Section 5 of this regulation on or before May 30 for the immediately preceding reporting period.

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Section 7. Method of Submission

All reporting entities shall submit the data in a manner prescribed by the commissioner.

Drafting note: States should develop a method for collecting data electronically, either through a database in which entities can log in to report or through a dedicated email address, as well as methods of communicating requirements and any changes to the industry. Such method should be noted in Section 7.

Section 8. Confidentiality and Sharing

Information filed with the commissioner relating to the experience of a particular agent shall be kept confidential unless the commissioner finds it in the public interest to disclose the information required of title insurers or title insurance agents under this section.

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Section 8. Confidentiality and Sharing (cont.)

In order to assist in the performance of the commissioner’s duties under this chapter, the commission may share data and information submitted by title insurance entities, including agencies, insurer direct operations, and title agent attorney firms, pursuant to Title Agent Statistical Plan data calls and collections, with other state, federal, and international regulatory agencies, with the National Association of Insurance Commissioners, its affiliates or subsidiaries, and with state, federal, and international law enforcement authorities, provided that the recipient agrees to maintain the confidentiality and privileged status of the information. Additionally, nothing contained herein shall prohibit the commissioner from sharing or publishing data in an aggregate form with the above parties or any other stakeholder.

Drafting note: States should ensure that the language that they use does not, nor can be construed as attempting to, limit the sharing or publication of aggregated data, since such publication may in fact make important disclosures regarding the experience of title agents in a particular geographic area or business demographic (i.e. by county, state or by agency type.)

Furthermore, states should contemplate whether or not they intend to publish aggregated data and the extent to which they are prepared to be required to publish or just may publish, etc.

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Section 9. Enforcement

The commissioner may require that the information provided under this section be verified by oath of the insurer’s or agent’s president or vice president or secretary, as applicable. The commissioner may further require that the information required under this section be subject to an audit conducted by the commissioner. The commissioner shall have the authority to establish a minimum threshold level at which an audit would be required.

Noncompliance with this regulation may result, after proper notice and hearing, in the imposition of any of the sanctions available in the (insert state) statutes pertaining to the business of insurance or other laws which include the imposition of fines, issuance of cease and desist orders, and/or suspensions or revocation of license. Among others, the penalties provided for in (cite appropriate state laws concerning failure to respond, unfair business practices, etc.) may be applied.

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Section 10. Severability

If any of the provisions of this regulation shall be held invalid or unenforceable, this regulation shall be construed as if not containing such provisions and the validity, legality, and enforceability of the remaining provisions shall not be affected or impaired in any way.

Section 11. Effective Date

This regulation is effective on [insert date] and applies to all transactions entered into after the effective date.

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NAIC PLAN - DETAILS



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New Jersey is moving to adopt a statistical plan*

Interest for data collection in Florida*

New York and Pennsylvania issued their own data calls in early 2010 (Jeremy Yohe, Creation of a National Title Agent Data Call, Title News, Vol. 89, No. 6, June 2010, at 8.)

NAIC survey indicated that only 11 states, and Puerto Rico, intended to participate in the NAIC Plan:*

Alaska Arizona Colorado Florida Michigan Minnesota New Hampshire New Jersey Nevada Puerto Rico Tennessee Washington

*ALTA Advocacy Update (Dec. 28, 2011) reported

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Title insurance coverage is retrospective from the policy’s effective date and remains in force throughout the term of a loan or the ownership of real property. Policies are issued once the Title insurance professional has addressed issues that adversely impact marketability of the title have been identified, addressed or resolved prior to policy issuance.

In contrast, P&C insurance coverage is prospective, identifying a finite future period with a definitive expiration date, as the coverage period for covered incidents that arise during the term of the policy. Events occurring prior to the effective date are excluded as are those that occur subsequent to the expiration date.

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The coverage timeframe differential in conjunction with a misunderstanding of the nature of Title insurance curative activities are ignored by existing and proposed reporting requirements.

As a result, the value proposition of Title insurance can not be properly presented, captured or understood.

The target loss and loss adjustment expense ratio for Title insurance is zero.

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Subject to the exclusions from coverage, the exceptions from coverage contained in Schedule B and the conditions and stipulations, the Title Underwriter, as of the effective date, insures against loss or damage…

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In Consideration of the Provisions and Stipulations herein, Property and Casualty Insurance Company, for the term of Effective Date at 12:01 a.m. to Expiration Date at 12:01 a.m., does insure…

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Title

Retrospective

Incident must have occurred prior to policy period and remain unresolved prior to policy issuance to be considered

Property & Casualty

Prospective

Incident must occur within policy period to be considered

Effective Date of P

olicy

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Loss adjustment expenses can be considered “allocated” or “unallocated”. (Defense and Cost Containment or Adjusting and Other)

Allocated loss adjustment expenses are expenses, such as attorneys’ fees or incident specific legal costs, that are incurred in connection with the investigation and analysis of a incident that has been reported to the insurer.

Unallocated loss adjustment expenses are claim department overhead. They are related to maintaining a claims function but not readily assignable to a specific incident. Examples include salaries, utilities and rent.

Unallocated loss adjustment expense is the cornerstone of effective Title insurance risk mitigation, yet it is not captured in current or proposed financial or statistical reporting.

In other words, given Title insurance’s retrospective coverage, what the Title insurance industry characterizes as “curative effort” would be considered loss adjustment expense in the P&C insurance industry.

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Examination◦ Legal Description◦ Conveyances◦ Execution◦ Notarization◦ Evidence of fraud, forgery, competence, etc.

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Order Entry◦ Verify property address◦ Verify owner(s)◦ Legal description of the property

Run the Chain of Title◦ Run names and nicknames◦ Determine if encumbrances exist, is an unallocated loss adjustment

effort but the activity to address them is allocated loss adjustment expense.

◦ Legal incompetence, conservatorship, bankruptcy, etc.◦ Impairments in chain of title◦ Enumerate adverse claims◦ Interests which affect tenancy◦ Property tax paid or in arrears, i.e., lien

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Matters Affecting◦ Covenants or restrictions◦ Easements◦ Rights of first refusal◦ Judgment or lien◦ Market requirement to cure◦ Indemnities◦ Review prior transaction◦ Application of statute of limitations

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Matters Affecting (cont.)◦ Update for last minute items◦ Review tax certificate◦ Reconcile difference with tax discrepancies◦ Check for outstanding tax sales◦ Review survey for adverse matters◦ Verify legal access◦ Mineral reservations◦ Geographic posting

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Once an incident is uncovered, through the expenditure of unallocated loss adjustment expense, the time, effort and expense associated with resolving or underwriting the incident should be considered allocated loss adjustment expense.

Effort and expense attributable to resolving a specific incident identified during the investigation of marketability of Title, i.e. Commitment.

Addressing specific defects, incidents or matters referenced in Schedule B-1 or B-2. (minimum)

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State Policies in Sample Incidents Discovered and Resolved

Colorado 83 888

Florida 43 248

Louisiana 114 585

North Carolina 270 3,323

All Samples Combined 510 5,044

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* Title estimates are based on one state study completed by Demotech, Inc.

Given the retrospective nature of a Title insurance policy, appreciable loss adjustment expense – unallocated and allocated – must be expended PRIOR to policy issuance. This effort resolves matters that could otherwise be presented as claims SUBSEQUENT TO POLICY ISSUANCE!

Unfortunately, current and proposed financial and statistical reporting requirements are focused on recording results as if a prospective P&C policy had been issued. Similarly, the NAIC Plan misses the mark by focusing on financial results rather than risk mitigation efforts.

These reporting formats overstate the Title operating expense ratio and understates the Title loss adjustment expense ratio, by the same amount. Under these circumstances, the value proposition of Title insurance can not be properly evaluated, presented nor understood.

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Continue to do whatever we can to educate regulators, legislators and consumers on the fundamentals of title insurance

ALTA Title 101 Louisiana Land Title Association

When your goal is a loss and loss adjustment expense ratio of zero, what will regulators do or say if you get there!

For copies of this presentation, contact Irisa Wasson, [email protected] or 614-526-3080.

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1. U.S. Government Accountability Office. April 2007. Title Insurance: Actions Needed to Improve Oversight of the Title Industry and Better Protect Consumers. Publication No. GAO-07-401.

2. http://www.gao.gov/products/GAO-07-401; see also NAIC, Title Insurance (C) Task Force. Conference Call, Sept. 1, 2011. Project History: Title Agent Statistical Data Plan Implementation Guideline. (“Project History”).

3. http://www.naic.org/committees_c_title_stat_plan.htm.

4. Project History, supra n. 4.

5. NAIC, Joint Executive (Ex) Committee/Plenary. Oct. 11, 2011. Summary Report. http://www.naic.org/meeting1108/summary_joint_ex_plenary.htm.

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joseph l. petrelli, acas, maaa, fca president, demotech, inc. arkansas land title association

Documents

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naic plan purpose

title industry

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title underwriters

chief insurance regulators

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oversight of title agents