THE PATRIOT ACT
The Patriot Act (Pub. L. 107-56)
What Our Agents Need To Know
Many of you have already received requests by mortgage companies for the “form” for their compliance with the Patriot Act. At present, title insurance companies are not required to implement an identification procedure, and we have not promulgated any such “form”. It is the lender’s responsibility to implement a procedure for identifying their customer.
ORNTIC’s requirements for identification are two forms of identification at or before closing, one of which has a picture and is government issued. In addition, the customer should be checked against the Specially Designated National List. ORNTIC provides the Specially Designated National list on ORLINK in a searchable format. Go to our New England Area homepage at www.ortboston.com or ORNTIC’s national homepage www.oldrepublictitle.com, and click on “Visit ORLINK”. Then click “Executive Order 13224”. Immediately contact the ORNTIC state office if a listed name comes up in the transaction. Check also those names who will be receiving money from your settlement but are not the buyer or seller.
You are encouraged to visit the Treasury Department’s Office of Foreign Assets Control (“OFAC”) website to familiarize yourself with the requirements and penalties of OFAC. Their website is www.treas.gov/ofac, then click on “Regulation by Industry”, then click “Insurance”.