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All out-going wires sent from the Company's escrow trust accounts must be approved by two authorized bank signers before they are sent to the Operational Accounting Center (OAC). The OAC requires two more approvers to review the wire for accuracy against the source document before sending it out.

Here is how the process works: The person sending a payoff wire verbally verifies the wire instructions at a known, trusted phone number and documents when and who they spoke to so anyone looking at the file knows the wire was verified. If the wire instructions appear on the repetitive wire list documentation is noted. 

Next, the demand is read thoroughly to ensure the full amount necessary to pay the loan is being sent. Then they ensure the file is fully funded and will not be overdrawn by the disbursement. Finally, the wire up is set-up in the system. Once the wire has been set up a second bank signer is required to verify all the same items and confirm the information entered is correct. They must ensure the routing number and account number are correct. They must make certain the correct loan number and borrower name is referenced before approving the wire to be released to the OAC. 

The payoff demand must be uploaded to smartview. Once the approved out-going wire request is received by the OAC, they too will verify the wire instructions against the repetitive wire list. If it does not appear on the repetitive wire list, they look for evidence the wire instructions were verified. Next, they read through the demand to ensure the wire will pay off the loan per the written demand or estoppel. The OAC verifies the routing number and account number are correct against the demand. They check the correct loan number and borrower name is referenced. When each person does their part, the process protects the Company and ultimately our customers. 

Recently, one of our offices ordered a payoff demand from a mortgage company. The demand was ordered on April 25, 2022. It was received on April 27, 2022, via email. This payoff included wire instructions to a bank in New York. On May 2, 2022, an amended demand was received which included an increase to the amount of trust funds advanced by the mortgage company. The original demand reflected an increase in advanced funds in the amount $103.72, and the new amount was for $207.72. No other amounts on the demand changed. On May 4, 2022, the office received an "updated" demand by eFax. Unknown to the office, this "updated" payoff had altered banking information to send funds to a bank in California rather than the bank in New York. 

The file closed and the wire was set up and approved at the branch and sent to the OAC for processing. The wire transfer was in the amount of $149,546.13. DeeDee Kelly, an amazing member of the OAC team, reviewed the wire. She compared the wire instructions against the payoff demand and the Company's repetitive wire list. She did not find a match, so she combed the escrow branch file looking for evidence the wire instructions were verified at a known trusted number. She did not find it. The wire request was returned to the branch. The branch contacted the mortgage company who confirmed the payoff demand had been altered. They had no record of that payoff demand having been set by their office on May 4, 2022. 

DeeDee is our hero! She followed the Company's standard operating procedure which proved once again to be our best defense against wire fraud. Great job DeeDee. She is being rewarded $1,500 for her efforts. Never skip a step and be sure to completely review each demand for discrepancies. Any changes should be verified before proceeding.

Article provided by contributing author:
Diana Hoffman, Corporate Escrow Administrator
Fidelity National Title Group
National Escrow Administration

 
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