Monthly Archives: September 2015



CALIFORNIA TITLE COMPANY is proud to announce that in July of 2015 it has completed its SOC 2 Type II Independent Service Auditor’s Report (SSAE 16) examination and was certified with “NO EXCEPTIONS” to the ALTA “Best Practices” protocols.

So what does all of this really mean?
In simple terms the CFPB has released a set of rules and regulations with which the Lenders must comply. This is all to protect the consumer including their personal information (NPPI) and more. Part of the Lenders criteria to be compliant is to make sure their third party vendors such as California Title are fully compliant and have the strictest regulations in place. It is becoming critical to choose a company that has achieved an SSAE 16 Certification. There are many facets to the “Best Practices” protocols. As part of our mission to the Real Estate Lending Industry and commitment to our clients we strive to deliver the best product possible. By going through an extensive six month auditing process twice, we are able to provide Lenders with the security that the SSAE 16 report provides.

California Title was among the first companies (Q1, 2014)
to receive the SSAE 16 reports

Another example of how we work hard for real estate professionals
and the consumers we serve!

For more information please contact your California Title Sales Rep.

For more information about CFPB and the changes coming October 3rd, please visit CFPB page on our website.

“Mortgage industry to CFPB: Stop normalizing bad data”

Mortgage industry to CFPB: Stop normalizing bad data

Fix the consumer complaint database, industry says

Link to original article | Written by Trey Garrison | September 2, 2015


The mortgage finance industry is still not happy with the Consumer Financial Protection Bureau and its consumer complaint narrative database, which publishes unvetted and unverified anonymous complaints against specific companies.

The database published by the CFPB contains complaints from consumers about companies, and the only verification is that there was a transaction between the complaining party and the company.

No effort is made to verify the substance of the complaint, and since much of the complaints regard private financial matters, companies are unable to offer contrary evidence for fear of violating consumer financial privacy, industry voices say.

“The CFPB is currently in the process of reviewing all comments that have been submitted,” a CFPB spokesperson said.

The Mortgage Bankers Association, National Association of Federal Credit Unions and the Consumer Bankers Association have all sent letters in the past 10 days to the Washington regulator.

The MBA’s letter reiterates its strong objections to the current structure of the Bureau’s Consumer Complaint Database and offered several recommendations to improve the database.

The letter, in response to a CFPB request for information regarding “possible normalization” of data contained in the Database, urged the Bureau “at minimum” to issue a new Request for Information regarding the Database.

“While we strongly object to the public display of unsubstantiated complaint narratives in the database, MBA believes taking the several steps we recommend, including seeking further comment, could improve the Database,” wrote MBA Senior Vice President Public Policy & Industry Relations Steve O’Connor. “Should the CFPB develop specific options to normalize this data, we urge at minimum the issuance of a new RFI.”

The letter noted MBA’s support of the CFPB’s efforts to assist consumers in making responsible financial choices and its establishment of a portal or gateway so companies can give prompt attention to complaints from consumers filed with the CFPB. MBA reiterated the industry’s efforts and financial resources into receiving, understanding and responding to consumer feedback.

“Companies are in constant communication with their customers, through multiple channels, to improve the customer experience,” the letter said. “Additionally, they have built reporting, analytics, and other platforms that enable them to enhance customer engagement and expeditiously address any complaints.”

Likewise, Richard Hunt, president and CEO of the Consumer Bankers Association, sent a letter to the CFPB in response to the request for comments.

“The CFPB has a fundamental duty to publish accurate, reliable information,” Hunt said.  “Publishing out of context, unverified data will only mislead consumers.  As outlined in the letter CBA submitted yesterday, we urge the CFPB to shift their focus.  They must verify the data before they work to normalize it because only then will consumers truly benefit from the ‘complaints.’ ”

Here’s a portion of the letter:

Our concern, however, is the potential misinformation generated by the Database.  Out of context, unverified data has the potential to mislead consumers away from financial institutions that may offer products and services that would benefit them. While industry has long advocated for normalization, we continue to be concerned consumers are being misinformed by unverified data; stress the importance of cautiously assessing how to properly normalize data; and urge the Bureau to adopt informed disclosures to promote transparency in the marketplace.

To view CBA’s whole letter, click here.

Just last week, NAFCU led off, letting the agency know about their problem with the program. NAFCU Regulatory Affairs Counsel Kavitha Subramanian sent a letter the bureau saying the database undermines the ability of businesses to resolve problems.

“Credit unions have a strong track record of working closely with their members to resolve any disputes or concerns…Given the credit union industry’s acute attention to complaint resolution, NAFCU and our members support the Consumer Financial Protection Bureau’s (CFPB) efforts to facilitate a dispute resolution process; however, the Database continues to have practical implications that undermine the complaint resolution process,” said Subramanian.

Here are the basic rules on complaints and narratives.


  • Complaints are listed in the database after the company responds to the complaint or after it has had the complaint for 15 days, whichever comes first.


  • The CFPB will disclose the consumer narrative when the company provides its public-facing response, or after the company has had the complaint for 60 calendar days, whichever comes first.

As of June 1, 2015, the Bureau has handled more than 627,000 complaints, with mortgages and debt collection being the most frequent topics.

The MBA and NAFCU both said back in July 2014 that they believed making the CFPB’s consumer complaint database public wouldn’t serve consumers or financial institutions.

“Adding unverified consumer narrative to the CFPB complaint database will not help consumers select a financial services provider,” Pete Mills, senior vice president of residential policy and member services at the MBA told HousingWire at the time.

“Would people pay for Angie’s List if they excluded all the positive reviews?,” Mills said. “Without context, a database full of complaints does not provide useful information to shop for financial services.”