As a result of the "FILE–to–file transfers" story and others just like it, FNF's corporate audit director, Melissa Alex, decided to share the following message with our readers.

The importance of the escrow disbursement reviews and second signatures seems to have been lost for some escrow officers. It is imperative that escrow officers understand the duties of an authorized trust account signer extends past simply signing their name. Regardless of the amount, two signatures are required on all escrow checks and outgoing wires, and all disbursements require supporting documentation.

If you are approached with a disbursement to approve that does not include any documentation, DO NOT SIGN THAT CHECK or authorize the wire. Authorized bank signers are held accountable for each and every check they sign/approve. That means if you sign a check without completing the proper due diligence, you have not fulfilled your responsibility to the Company and risk being implicated in the crime in the event the disbursement is fraudulent.

A good question to ask is, how does this disbursement relate to this transaction? If you do not understand the relation, ask questions and get comfortable with the answers prior to giving your approval. This might not always be easy, as at times you might be reviewing disbursements made by someone superior to you. However, if they are acting in good faith, they should gladly answer your questions until you are comfortable with giving your approval.

Those individuals doing the right thing will respect you more as being a diligent reviewer and ensuring you are keeping the Company's best interest in mind when you are reviewing their escrow file. Those individuals that get upset with your questioning or refuse to answer your questions might not be acting in the best interest of their customer or the Company and you should bring your concerns to the operation manager or others in upper level management. It is your responsibility to complete a proper review, so think twice the next time you sign off on any escrow disbursement.