DISB Insurance Commissioner Philip Barlow has responded to DCLTA's
letter regarding the proposed DC settlement agent rate examination. The
response can be read at the following link: DISB's Response to DCLTA 021915.
I am certain you will agree that the response is somewhat
disappointing, it also sheds some light on DISB and Mr. Barlow's
expectations from the process. In particular, Mr. Barlow states, as
follows: "I also want to reiterate that the purpose of looking at
from individual producers is not intended to be a compliance audit.
Rather, we are using the examination format as the safest and most
effective method of getting the information needed for Mr. Birnbaum' s
charge and to better enable the DISB understand the elements necessary
to carry out our responsibilities under District law for reviewing rate
filings." He also notes his interest in DCLTA's future presentation on
rate avoidance issues specific to DC settlement practice.
are preparing the presentation and hope to get a date on the calendar
for March to meet again with DISB for this presentation. DCLTA will
need your assistance in preparing for this. In particular we are
looking for an "in the DC trenches" perspective on your most pervasive
DC risk avoidance problems; practical examples of these issues; and, any
memos, guidelines or other written material that will illustrate the
problems or necessary remedial processes. In our last letter to DISB
we included an outline of some such issues. A copy can be reviewed at
this link: DC Title Considerations. Please contact me if you are able to assist us in moving this process forward.
As always if you have any questions let us know and if you are able to help, please do hesitate to contact me.
DC Land Title Association
Mike Russo, Presidentmailto:russo@CouncilBaradel.com