HOW WE CONDUCT AGENT VETTING AND WHY?
Settlement Agents have access to a lenders funds and important security documents (note and mortgage). They also have access to a borrower’s complete personal and financial history (on the Loan Estimate and Closing Disclosure) including their SSN, DOB, home address, place of business, bank accounts and assets. Prudent risk management and regulatory consumer protection directives require lenders to know their partners and evaluate and monitor them for risk at all times. Documented procedures and reports must be available when audited. While these professionals may be licensed, be an association member, or have contracts with large insurers, this is not an acceptable substitute for independent risk evaluation and monitoring required of lenders by government regulators.
WE VERIFY IDENTITY
Lenders and consumers need to know who is representing them at the closing. Regulators require banks and lenders to “know their third party service providers.”
SSI has uncovered SSN fraud and identity manipulation to hide license and criminal activity histories.
WE VERIFY AND TRACK ALL LICENSES
Where licensure is required by state or federal law, we check status and disciplinary history
SSI has uncovered many instances of unlicensed professionals and others with serious license disciplinary issues directly related to real estate settlement responsibilities.
WE VERIFY BACKGROUND
Risk of potential fraud or other loss is statistically related to certain personal and business background factors that we check and monitor 24/7.
SSI has uncovered numerous instances of agents named in active fraud cases, subject to criminal indictments and convictions, and with significant financial issues due to IRS tax liens and large civil judgments that create actual and potential risk issues.
WE VERIFY AND TRACK INSURANCE
Lenders and their warehouse banks require certain minimum levels of insurance to receive mortgage proceeds. In addition states have varying professional insurance and surety bond requirements. Certificates of insurance can be altered and amended and must be verified.
SSI has discovered uninsured and underinsured agents, and discovered altered certificates of insurance with enhanced coverage limits and changed expiration dates.
WE VERIFY TRUST ACCOUNT DETAILS
Lenders wired over One Trillion Dollars into trust accounts last year in connection with residential mortgage closings. They, their investors and warehouse banks, and certain state regulators, have trust account requirements: separate account from operating account, managed accounting (no NSFs), proper reporting and disbursement history.
SSI has uncovered commingled accounts (trust and business in same account), personal account being used as trust accounts, and trust account mismanagement (overdrafts and fraud investigations).
WE VERIFY INTERNAL CONTROLS
Regulators require that lenders verify that their third party service providers adhere to consumer protection and data privacy laws, especially since they have access to a borrower’s personal and financial information in connection with the settlement of loans.
SSI has encountered many businesses especially small businesses that have no knowledge of these important requirements. In these cases SSI has provided sample policies and procedures to assist them in becoming compliant while serving their lender client regulatory expectations.
WE MONITOR RISK IN REAL TIME
SSI monitors all public data in real time through proprietary technology, using a cross reference of public data aggregators and using on-staff, trained risk analysts based in the United States. All private data is re-verified through quality control efforts on an ongoing basis, and every agent is renewed with a complete re-vetting each year. Any changes in risk status are reported. No data is stored, analyzed, transmitted or accessed by any person or entity outside of the USA.
WE RATE RISK NOT JUST REPORT DATA
SSI actually reviews, evaluates and assigns a risk rating to each professional entity and individual we rate. The risk rating is the result of a complex set of proprietary metrics developed jointly between the founder of the company and risk analysts at certain syndicates at Lloyd’s of London®. SSI also allows lenders to rate performance on a transaction basis so that SSI’s data reports give lenders the full picture: risk and competency to evaluate possible losses from fraud and negligence.
WE STORE DATA IN A SEARCHABLE DATABASE
SSI enters all vetted agent data into a shared, searchable database known as CASE™ that is accessible to SSI bank and lender clients 24/7-365. The database contains basic agent information as well as an SSI risk rating: low, medium or high, based upon search results and updates.
WE OFFER AN AGENT APPEAL PROCESS BEFORE ANY DEROGATORY INFORMATION IS PUBLICIZED
SSI voluntarily complies with the spirit of FCRA by not a publishing any derogatory information before notifying an agent and obtaining their cooperation in verifying the accuracy of the data. Likewise any changes in an assigned risk status (due to new data coming to light) are only made public after notifying an agent and again seeking their input in corroborating what has been found. Our direct interaction with professionals helps assure the accuracy of our information for all parties.
PRIVACY PROTECTION IS OUR FOCUS
SSI’s approach to risk management is independent, comprehensive, proven and validated by third parties. SSI voluntarily complies with FCRA rules in that no derogatory information uncovered in any evaluation is ever published without an automatic appeal and right to explain/correct/supplement by the vetted agent. SSI adheres to strict data security and privacy rules. All information obtained from vetted agents is stored on secure servers and backed up to the Cloud using ARMOR technology. All SSI employees are themselves screened, and the workplace is secure and monitored. Private data is handled in accordance with the protocols established by international standards: SSI complies with PCI, IAPP and SOC II data privacy control requirements. It’s internal financial, operating, and data controls have been inspected and annually certified by a CPA firm to meet SSAE16 requirements (successor to SAS70). SSI carries appropriate errors & omissions insurance and cyber liability coverage.
The SSI risk platform has been evaluated and approved by certain syndicates of Lloyd’s of London® to support Mortgage Settlement Insurance™ covering lenders, investors and consumers from risk of loss from fraud and certain negligence in connection with residential closings. SSI is the only company that has been endorsed by Lloyds for the accuracy and value of its risk management platform.