Licensing and Registration Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 1)

It is the company policy of Sakson Settlements (Sakson) to establish and maintain any and all registrations and licenses, and to comply with the filing requirements of all federal and state agencies in order to conduct the business of title insurance and settlement services in a lawful and uninterrupted manner.

This Licensing and Registration Policy is updated as may be required by changes to state and/or federal statutes and regulations. It is also the Company’s policy to train and educate its staff members of these requirements.

The following items are currently maintained in order to comply with this policy, with copies available upon request:

Certificate of Good Standing from the Maryland and Virginia Secretary of State.

Fidelity National Title Insurance Company

American Land Title Association Certificate of License for the current year.

Maryland, Virginia and District of Columbia Insurance Licenses issued by the appropriate authorities.

Copies of current Notary Public Commissions of all staff members holding a Notary Commission.

Escrow Accounting Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 2)

As a real estate settlement agent, Sakson Settlements (Sakson) is entrusted with money belonging to sellers, buyers and mortgage lenders in real estate transactions, as well as owners and mortgage lenders in construction projects. The protection of the money entrusted to Sakson is of extreme importance to the protection of those parties to real estate transactions.

In order to properly protect the money that Sakson is entrusted with, the Company has invested in and implemented escrow accounting procedures and security measures that currently exceed the ALTA Title Insurance and Settlement Company Best Practices requirements. These procedures and security measures include and address proper segregation of duties, daily three-way reconciliations, a separate incoming wire escrow account, anti-fraud security measures for both checking activity and wire activity, payee positive pay, obtaining criminal background checks on employees, and handling of stale-dated checks, in addition to the many other individual procedures that provide the expected level of protection of our escrow accounts that a responsible title insurance and settlement agency should have in place.

The Company views these procedures as an ongoing process of improvement. As technology improves and greater security measures are developed by our software vendor(s), our bank(s), any of our underwriting companies, or any other source, the Company will make enhancements to these procedures as needed.

Privacy and Information Security Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 3)

As a title insurance and real estate settlement agent, Sakson Settlements (Sakson) is required under the Gramm-Leach Bliley Act to develop a written information security program that describes the procedures it employs to protect Non-public Personal Information (NPI). Sakson is entrusted with the NPI of consumers who are sellers or buyers of real estate, as well as mortgagees in real estate lending transactions. The protection of the consumer’s NPI entrusted to Sakson is of extreme importance to the protection of all parties to real estate transactions and it is the policy of Sakson to comply with all Federal and State laws governing the protection of NPI.

In order to properly protect consumer NPI, Sakson has invested in and implemented: General offices security measures to specifically address the individual security measures needed for each of company offices, including a clean desk policy; Physical file security procedures to protect each physical file being worked on whether in an Sakson office, a customer’s office, the county courthouse, or in transit to any of those locations; Computer system and technology security procedures; Strong password policy; Handling of consumer NPI; Use of a high security level data center; Disaster Management and Recovery; Management, oversight, internal auditing and security breach notification.

The Company views these procedures as an ongoing process of improvement. As technology improves and greater security measures are developed by our software vendor(s), our bank(s), any of our underwriting companies, or any other source, the Company will make enhancements to these procedures as needed.

Terminated Employee Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 3)

It is the company policy of Sakson Settlements (Sakson) to protect any and all Non-public Personal Information (NPI) of any consumer as required by local, state and federal law. Sakson will protect, maintain and monitor the security of, but not limited to, all company offices, files, computer system data, computer equipment including mobile computing equipment, bank accounts including escrow checking accounts, and any other Company information, data or property.

Upon the termination of any Sakson employee, whether voluntary or involuntary on the part of said employee, that employee’s direct supervisor will follow the company protocol to eliminate that employee’s access to all physical office locations, eliminate that employee’s access to all Company files, disable that employee’s access to all Company computer systems, disable that employee’s access to the Company’s escrow accounting and banking systems, remove said employee from any and all bank account signature authorizations, and eliminate all other access said employee may have. The Company views these procedures as an ongoing process of improvement. As technology improves and greater security measures are developed by our software vendor(s), our bank(s), our equipment vendor(s), our underwriting companies, or any other source, the Company will make every effort to enhance these procedures as needed.

Document Recording Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 4)

Legal documents affecting interests in real estate are entrusted to Sakson Settlements (Sakson) on a routine basis as a part of the normal course of business. Upon receipt of any legal document(s) by any Sakson staff member or office, whether by hand delivery, regular mail delivery, overnight Currier, electronic transmission, or any other method, said legal documents must be handled appropriately and in a timely manner. It is the company policy of Sakson to examine legal documents for accuracy and insurability, then submit said legal documents for recording to the appropriate county recorder within two days of receipt of said documents and the appropriate recording fees, regardless of whether Sakson conducts the closing or said documents are submitted to Sakson after a closing is conducted by another entity.

Pricing Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 4)

Sakson Settlements (Sakson) is a Maryland based title insurance and settlement services agency and conducts most of its business on real estate located in the State of Maryland, Virginia and District of Columbia. Sakson Settlement also conducts and handles transactions on commercial and industrial real estate located in Maryland, Virginia and District of Columbia. It is the policy of Sakson to follow and comply with any and all title insurance rate schedules required by the State departments of insurance, or any other regulatory agency that governs the title insurance industry, where Sakson conducts business.

Title Policy Production and Remittance Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 5)

The issuance of title insurance policies in a timely manner is a critical step in the completion of any insured real estate transaction. On every transaction that Sakson Settlements (Sakson) insures, whether or not Sakson closes the transaction, the issuance of the title insurance policy must be done within 30 days of the settlement and/or recording of the documents to be insured, and all of the conditions of the title insurance commitment have been satisfied.

Along with the issuance of title insurance policies, reporting the transaction to the title insurance company and remitting the underwriter portion of the title insurance premium, Closing Protection Letter (CPL) fees, and any policy fees required by state statute, is critically important. It is the policy of Sakson to utilize the electronic policy jacket capabilities of its underwriting companies, which allow for the immediate reporting of the transaction, issuance of the title insurance policy or policies, total premium collected, amount of premium to be remitted, and CPL fees collected and remitted in a timely manner.

Insurance Requirement Policy

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 6)

It is the company policy of Sakson Settlements (Sakson) to maintain appropriate professional liability insurance or Errors & Omissions insurance, and fidelity insurance covering employee theft in order to meet its contractual obligations with the title insurance underwriting companies that Sakson is an authorized policy issuing agent of. Sakson also issues Closing protection Letters (CPL’s) in all settlement transactions where Sakson is acting as the settlement agent in accordance with the State Title Insurance Act.

It is also the policy of Sakson ownership and management to review the types of coverage needed and the limits of insurance policies on an annual basis as a part of the annual renewal process coordinated with the appropriate insurance agencies it works with.

Consumer Complaint Procedure

(Pertaining to ALTA Title Insurance and Settlement Company Best Practices, Version 2.0, Pillar No. 7)

It is the company policy of Sakson Settlements (Sakson) to receive, address and document consumer complaints in a timely and professional manner. A log of customer complaints is maintained by and within each office.

Sakson Settlements

6926-B Little River Turnpike
Annandale, Virginia 22003

sakson@saksonsettlements.com

(703)-941-1850

965-C Russell Avenue
Gaithersburg, Maryland 20879

sakson@saksonsettlements.com

(301)-977-9770

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