comment to CFPB

I am a title insurance agent. I operate what might be considered a small regional agency. I have had roughly $22,000,000.00 move through my escrow account YTD. The procedures I have in place to account for and safely guard these funds were developed with little or no oversight. These funds include down payments collected from home buyers, proceeds of home sellers, mortgage payoffs and incoming mortgage funds to be disbursed as part of federally related mortgage transactions. I also receive with each mortgage transaction a full mortgage application accompanied by other sensitive consumer data such as tax returns, paystubs or bank statements. I retain copies of these documents in paper and electronic form. I believe consumers have a false sense that the funds and information we collect are safe because we are seen as an extension of the mortgage transaction and also because I think there is a presumption that our business must be subjected to some form of regulation. Beyond state licensure and some oversight by underwriters, we are on our own. I am honest and careful. I have a background in banking where I learned how to manage money and data. Many in my business have no such background and no guidelines to follow. My authority to provide such consumer financial products and services comes from my position as an agent of a title insurance company. Though the business of insurance is not covered by CFPB, settlement service providers are and I mean by these comments to direct attention to the large volumes of money and data moving on  and off shore through these companies and their agents. How do you define a large participant in this business? I would tend to say any agent or sub-agent or a title insurance company who conducts more than twenty transactions per month – or 240 per year – could be considered a large participant. This is arbitrary, of course, but it would at least capture oversight of those likely to do the most damage. Diane Cipa, dcipa@tcsclosing.com