October 24, 2024
In This Issue:
- Update: TDI's Public Meeting on Title Insurance Rates
- TDI Quarterly Audit Results Published (June - August 2024)
- FinCEN Renews Real Estate Geographic Targeting Orders
- Reminder: Statistical Code Changes Will Not Be Implemented Until Jan. 1, 2025. It's Not Yet Necessary to Begin Tracking and Reporting New Endorsements That You Issue
Update: TDI's Public Meeting on Title Insurance Rates
TLTA | Oct. 23, 2024
As part of TDI's ongoing review of Texas title insurance rates, the agency held an informal public meeting Oct. 22 so Commissioner Brown could hear input from interested parties.
We're pleased to report that a dedicated group of TLTA member volunteers from across the state and our team of actuarial and legal experts were able to tell our industry's story comprehensively and with sincerity. We're grateful TDI provided this opportunity to share our industry's perspective on marketplace realities that must be part of any discussion related to title insurance rates in Texas.
No ruling was made at this informal meeting but the rate review process continues and we are preparing for next steps. If you have questions, please send them to TLTA Vice President of Government Relations and Counsel,
Aaron Day.
TDI Quarterly Audit Results Published (June - August 2024)
TLTA | Oct. 23, 2024
The following is a summary of recent TDI audits, violations and enforcement actions from June through August 2024. Read TDI's complete summary of operations for the quarter, or review key statistics below.
Compliance Audits: TDI's goal is to comprehensively audit agencies at least once every two years. This quarter, TDI conducted 102 audits.
Commissioner Orders: This quarter, TDI signed two (2) Commissioner Orders.
Compliance Audit Results: Below are TDI's most common audit findings for the quarter that ended Aug. 2024. The numbers below represent how many agencies had an infraction, not the number of times the infraction occurred:
| Number of Agencies |
Description |
| 66 |
Section 2702.053 – Actual receipts and/or disbursements not in agreement with settlement statement or premium split not disclosed. |
| 52 |
Outstanding check not cleared timely |
| 40 |
P-73: Failure to prepare/maintain Form T-64 (TD) when CD used, or Form T64 was not signed by all parties. Prepared incorrectly. |
| 39 |
Title Bulletin No. 160 – All parties receiving portions of real estate commission not disclosed on settlement statement. |
| 38 |
P-21: Schedule D of commitment not in file or premium split not disclosed on commitment.
|
Read More »
FinCEN Renews Real Estate Geographic Targeting Orders
U.S. Treasury | Oct. 17, 2024
The Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate.
The terms of the GTOs are effective beginning October 16, 2024, and ending on April 14, 2025.
The following Texas counties continue to be included in the GTO:
Bexar, Dallas, Harris, Montgomery, Tarrant, Travis, Webb
Review FinCEN's Press Release »
Copy of the GTO »
GTO FAQs »
TLTA Editor's Note
FinCEN adopted new rules related to reporting requirements for certain all-cash residential real estate transfers, which will replace the current GTO program referenced above on Dec. 1, 2025.
The new reporting and compliance requirements will have a significant impact on you and your business when handling cash transactions. You should consult with legal counsel to ensure you fully understand your obligations under this new rule.
TLTA will produce detailed analysis and educational programming to help guide you as you prepare for this new rule. Let us know if you have questions.
Reminder: Statistical Code Changes Will Not Be Implemented Until Jan. 1, 2025. It's Not Yet Necessary to Begin Tracking and Reporting New Endorsements That You Issue
TLTA | Oct. 23, 2024
The Texas Department of Insurance has adopted changes to the Basic Manual of Rules, Rates, and Forms for the Writing of Title Insurance in the State of Texas, which will be effective Nov. 1. TDI also adopted changes to the Statistical Plan, which will be effective Jan. 1, 2025.
Stat codes for new endorsements not effective until Jan. 1, 2025
Stat codes for the new items adopted by TDI are not effective and so it's not ncessary to track or report issuance of these endorsements until Jan. 1, 2025. TDI will not start counting them until they're implemented -- TDI does not want us to include 2024 endorsement data in the 2025 year report.
Find all the Stat Code and Basic Manual changes adopted recently in TDI's final adoption order exhibits
Review all adopted changes in the final adoption order exhibits »
Want to compare the new changes with current rules and forms?
In order to view all the changes adopted in redline version, you’ll need to look in two places. Please review both pdf links below to ensure that you're aware of all of the changes.
1) Substantive Changes – Published May 2024
2) Minor Corrections - Published September 2024
- TDI made small corrections (typos and formatting) in the final order that was published and provided those changes separately.
- View Here
Key things to know about the changes referenced above
- Changes to the Basic Manual are effective November 1, 2024.
- Changes to the Statistical Plan are effective January 1, 2025.
- The adopted changes are substantively the same as the proposed changes published May 31. Only minor typographical corrections were made in the final adopted version.
TLTA tools and resources to guide you through these changes
Review all 10 of the installments in TLTA's Basic Manual update series »
Register for TLTA's on-demand webinar explaining the changes adopted today »
Background on TLTA proposals and process by which TDI adopted their changes »
Recognition of the many people who helped make these changes possible
A huge shoutout and hearty thank you to the team at Texas Department of Insurance, our
Regulatory Committee chaired by the stalwart Roland Love as well as the previous chair Peter Graff who led the launch of this process, TLTA Vice President of Government Affairs and Counsel Aaron Day, and the entire team of industry professionals who helped get this years-long project across the goal line. Great work, all!
Questions or comments?
If you have questions, please send them to
Aaron Day or call Aaron at 512.810.8800, thank you.