Vetting Push Back

vetting header

May 2015

To all our Respected Members:

Attached you will find the vetting pushback package that the National Affairs Committee (NAC) of our organization has put together for our members. With the 2015 vetting push back letter we include the following:

  1. Lender Vetting of Escrow Holders – Statement put forth by the Escrow Institute of California
  2. Licensing and Regulatory Stands for Independent Escrow Companies – put forth by the Escrow Institute of California
  3. Department of Corporations (now the Dept of Business Oversight) Commissioner’s Bulletin No. 001-12 re: Emergence of Third Party Risk Management Companies
  4. CFPB Compliance Bulletin 2015-01 – Treatment of Confidential Supervisory Information
  5. Letter to Commissioner Owen of Dept of Business Oversight dated March 6, 2015 with Notes and Analysis
  6. Escrow Institute of California letter of February 6, 2015 to Richard Cordray, Director of the Consumer Financial Protection Bureau American
  7. Escrow Association letter of Feb. 11, 2015 to Director Cordray
  8. State of Washington Dept of Financial Institutions letter regarding the vetting practice
  9. California Assembly Bill No. 1169 re: Escrow agent rating service
  10. California’s Buyer’s Choice Act
  11. Escrow Institute of California letter of Sept 25, 2012 to Andrew Liput of Secure Settlements Inc.

The vetting push back letter is a generic one that you can copy and paste to your letterhead and put your company’s name in the blank spaces. As stated in the letter you should provide them with a copy of your DBO license, your EAFC member letter, and a copy of your business license. Then, if you feel it necessary, you can print the list of attachments and put them with your letter.

We provide this to you in the hopes that it will help you in your efforts to reject the Lenders’ request for vetting, particularly when they ask you to submit your staff’s personal information to an unregulated third party vendor. HOWEVER, prior to using what we have provided it is important that you consult with your management and obtain your own independent legal counsel.

Let us know the names of those Lenders for whom you have had to submit this vetting package. Also let us know the outcome. This way we can keep a list of vetting Lenders and what works or does not work for each.

We thank you for your help on this crucial issue. Remember, TOGETHER WE ARE BETTER!

Nancy Silberberg             Vital Materials for Pushback Letters
2015 President