Bulletin: VA2018002

Dear Associates:

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.

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