- March 26, 2018
- All Virginia Issuing Offices
- RATES AND/OR FORMS UPDATE - Virginia CPL Charge Will Now Be Title Premium
Effective April 15, 2018, the charge for Closing Protection Letters (“CPL’s”) in Virginia will be considered by the Virginia Bureau of Insurance (“BOI”) as title premium, per:
- The attached BOI Administrative Letter 2017-04.
- Also see the attached letter dated January 11, 2018, signed by Chuck F. Myers, supervisor of the RESA Investigations Unit of the BOI.
Agents are to charge the $20.00 CPL premium on their CD’s or HUD-1’s labeled “CPL Premium” as a separate line item, with the payee as Stewart Title. The $20.00 CPL premium will still be remitted 100% to Stewart Title Guaranty Company, either as a separate $20.00 check, or multiple CPL payments on one check. Or, the CPL premium charge may be remitted with normal agency split reported to Stewart. The $20 CPL fee can continue to be an additional amount included in your title premium check.
Virginia Code §55-524 B mandates how agents are to disburse title premiums, and Virginia Code §38.2-1813A describes that agents are to remit “in the ordinary course of business”. Agents’ underwriting agreements are not affected by the new labeling of the premium charge.
If an agent has already quoted the $20 charge as a “fee”, it is not necessary to re-quote that fee as “title premium” but as of April 15, 2018, the BOI has mandated all CPL charges to be quoted, collected and remitted as outlined in this bulletin.
Please advise your realtors, loan officers and other customers of this small but significant change, so all TRID and other required disclosures can be done timely.
If you have any questions relating to this or other bulletins, please contact a Stewart Title Guaranty Company underwriter.
For on-line viewing of this and other bulletins, please log onto www.vuwriter.com.
THIS BULLETIN IS FURNISHED TO INFORM YOU OF CURRENT DEVELOPMENTS. AS A REMINDER, YOU ARE CHARGED WITH KNOWLEDGE OF THE CONTENT ON VIRTUAL UNDERWRITER AS IT EXISTS FROM TIME TO TIME AS IT APPLIES TO YOU, AS WELL AS ANY OTHER INSTRUCTIONS. OUR UNDERWRITING AGREEMENTS DO NOT AUTHORIZE OUR ISSUING AGENTS TO ENGAGE IN SETTLEMENTS OR CLOSINGS ON BEHALF OF STEWART TITLE GUARANTY COMPANY. THIS BULLETIN IS NOT INTENDED TO DIRECT YOUR ESCROW OR SETTLEMENT PRACTICES OR TO CHANGE PROVISIONS OF APPLICABLE UNDERWRITING AGREEMENTS. CONFIDENTIAL, PROPRIETARY, OR NONPUBLIC PERSONAL INFORMATION SHOULD NEVER BE SHARED OR DISSEMINATED EXCEPT AS ALLOWED BY LAW. IF APPLICABLE STATE LAW OR REGULATION IMPOSES ADDITIONAL REQUIREMENTS, YOU SHOULD CONTINUE TO COMPLY WITH THOSE REQUIREMENTS.