Escrow Back to the Basics* RESA Audits Part II (AC July 2025)

As a follow-up to our April article, we want to take a deeper look at Title Premium accounts and Recording accounts. 

1. Virginia escrow accounts to be styled:

• • Trust
  • Escrow
  • Recording
  • Title Premium

2. The Bureau of Insurance Common Problems memo goes over expectations of the BOI, to treat the Title Premium accounts in a Fiduciary capacity in the ordinary course of business to include monthly reconciliations and timely remittances of title premium to the underwriters per the Agency Agreement. The Bureau takes special notice because title policies may be delayed to the consumers and lenders, and title premium and policy copies may be delayed to the underwriter.

Note: The same Memo covers three ways in which title premiums may be kept because a separate title premium account may not be necessary eliminating additional paperwork.

3. During the annual RESA audit, auditors are to note any findings regarding Recording accounts not being 3-way reconciled. The BOI letter, dated January 4, 2017, explains a possible alternative to maintaining a separate recording account. Depending on which e-recording provider is used, paying with e-checks directly from the regular escrow accounts may be a solution, eliminating additional paperwork.

Remember to email VAAuditing@OldRepublicTitle.com with any audit or escrow questions.

*This list is not all-inclusive.