ALTA Best Practices Compliance

ALTA Best Practices Compliance2018-11-12T15:40:46+00:00

Be ahead of the field

CRI can help you put your best ALTA Best Practices compliance foot forward.

ALTA Assurance ChartFor the last few years, title and settlement companies and those associated with settling residential mortgages for lenders (collectively herein “title agents”), have heard about the importance of implementing American Land Title Association (ALTA) Best Practices. Meanwhile, the Consumer Financial Protection Bureau (CFPB) enforces its mandate for lenders to monitor their title agents’ compliance with applicable federal consumer financial laws. This confluence of events has caused lenders to hit the starting blocks and focus on and request (or require) compliance evidence. The evidence can be as simple as a sprint to self-assessment or as complicated as a marathon to third-party certifications. Some lenders are disqualifying title agents from the race and from their “approved list” for lacking documented compliance.

Get a leg up in the ALTA Best Practices compliance race by allowing CRI to coach you through our Readiness Assessment, a warm-up that:

  • assesses your race preparation,
  • analyzes your stride and points out any gaps in your preparation, and
  • coaches you with a specific remediation and race plan to become compliant.

The goal of the CRI Readiness Assessment is to help you avoid a false start. Once you’re in the blocks, we provide a compliance certification under the American Institute of Certified Public Accountants’ (AICPA’s) standards. We can help you with the dash of a review, the middle distances of an agreed-upon-procedures (AUP) engagement, or the long distance of an examination. Our goal is to help you find your form and most efficient mechanics during your third-party certification.

CRI, an ALTA Elite Provider and Fidelity National Title Group (FNTG) Preferred Provider, has industry-specific expertise led by our ALTA Best Practices team in 25+ markets to deliver a high level of responsiveness and accessibility designed to deliver a heightened client service experience. Let us help you find your stride.

3 Reasons to Choose CRI

Expansive network, industry expertise, & ALTA Elite Provider


with each area boasting a local partner designated for performing ALTA Best Practices compliance engagements. This network translates into a high level of responsiveness and accessibility.


providing a multitude of services to 150+ financial institution clients and IT audit & assurance services to 300+ companies. 


and has passed a rigorous approval process. As an Elite Provider, CRI provides effective solutions for ALTA members’ critical needs and is committed to offering comprehensive industry benefits.

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ALTA Best Practices Assurance Levels

Comparison of services

Determining the appropriate level of assurance is a risk-based assessment of various dynamics, including the title agent’s number of residential closings, offices, employees, escrow accounts, and underwriters.  So whether you perform a minimal number of closings (and may be low-risk), or you execute thousands of closings (and may be high-risk), the chart below can guide you in making the right decision about your needs.

Self-CertificationConsulting Engagement -Readiness AssessmentReview Engagement – less than 360 closings per yearAgreed Upon Procedures (AUP) Engagement – between  360 to  2,000 closings per yearExamination Engagement – greater than  2,000 closings per year
CPA Expertise  RequiredNoYesYesYesYes
CPA Level of AssuranceN/ANoneModerate Level of AssuranceReport of Procedures Performed and Results of ProceduresHigh-level of Assurance in all Material Respects
Anticipated ProceduresInquiryN/AYesYesYesYes
Analytics/Retesting Client TestingN/ANoneYesNoNo
Reading Policies & ProceduresN/ANoneYesYesYes
Examining/Testing Evidence of Policies & Procedures operatingN/ANoneNoYesYes
Onsite VisitN/ANoneDependsYesYes
Transparency (for user banks to understand procedures performed and results of tests)NoNoNoYesNo
Users of ReportN/AGenerally RestrictedUnrestrictedRestricted to Users Who Agree to Sufficiency of ProceduresUnrestricted
Engagement Fee RangeN/A$750, Standalone$4,000 – $5,000 Plus Travel$12,000 -$15,000 Plus Travel$17,500 and Above, Plus Travel
Readiness Assessment Included in Engagement FeeN/AN/AYesYesYes


Straight Talk

Translating technical jargon into a plain English “text.” 
None of my lenders have required me to become third-party certified in ALTA Best Practices compliance. Why should I start now?
Our conversations with many compliant title agents indicate that the certification process takes many months, if not years. Plus, the minimum period for testing is 90 days. Therefore, once you receive a lender’s 90-day letter, it’s virtually impossible to become certified within that period.
I’m starting to see the picture. What is the first step that I need to take?
We recommend a CRI Readiness Assessment, which defines your current level of compliance. We’ll also provide a gap analysis and remediation plan. The total package will allow you to begin remediating any identified deficiencies.
We have controls in place already. So, I think that I am ready to begin the actual compliance certification testing right now. Why do I need to take the Readiness Assessment?
Our experience with controls testing in general, and with ALTA Best Practices compliance in particular, indicates that almost all clients will have deficiencies and/or gaps that require remediation. Once the testing begins, both your team and ours must report what we find, and the controls either pass or fail. Given this, finding deficiencies right after you begin compliance testing isn’t a great starting point. Being proactive may keep you from identifying problems midstream, stopping your compliance testing, and remediating some deficiencies or, worse, reporting issues.
I get it. I perform only about 300 closings per year. Do I have to go through the same certification process as a medium or large agent?
Well, the various lenders have provided guidance about that. Based on that collective guidance, we’d say that the answer is “no.” However, we believe that all title agents should adopt ALTA Best Practices and scale policies and procedures based on their company’s risk, size, and other characteristics.Title agents should also adapt the Best Practices to their own business operations.
Can you help me to decide what level of certification report that I will need?
Well, the first thing we need to know is if your lender has required something specific. If not, then we’ll address a few factors to help you get to the right fit. These factors include (but aren’t limited to) the number of closings (in your case, 300), the amount of assurance you and the lenders desire, and the expected users of the report. We want to help you find the cost-effective solution.
I understand – we’ve got that information. When can we sit down and discuss next steps?
Let’s schedule a meeting for next week.

Client SNAPshot

CLIENT:Large title and settlement agent (20+ offices/multiple states)
SCOPE:New client in a highly regulated industry where regulators are requiring independent verification of compliance with federal consumer financial laws as evidenced by compliance with one of the industry’s accepted frameworks: ALTA Best Practices
PROJECTS:Examination services to provide certification about the title company’s ALTA Best Practices compliance
RETURNS:The client worked diligently for several months to demonstrate its compliance with the rules, but the project bogged down. By working with client’s personnel as a business partner and finding solutions to potential issues, CRI was able to complete the engagement and issue the certification approximately five weeks after the initial call.
Certification issued in 5 weeks

Solution Simplified

Down-to-earth descriptions of our services.

Readiness Assessment

In our Readiness Assessment, we’ll ask your team to provide us information regarding your ALTA Best Practices compliance efforts through an electronic tool aligned with ALTA’s 7 Pillars. This assessment will require your team to answer survey questions and providing supplementary evidence. This information will allow our team to determine where you stand, what holes/gaps exist, and what remediation steps are necessary.


Certification will be provided using ALTA Best Practices Assessment Procedures as the basis or benchmark. Based on the level of assurance requested or required by you and your lenders (and other factors), we have three options to provide the assurance that will allow for certification. Those three options are a review, an agreed-upon procedure (AUP), and an examination. All three of these engagement types are conducted in accordance with the American Institute of Certified Public Accounts’ (AICPA) professional standards, which include objectivity and independence.