[Wltamembervoting1] Request for Regulatory Review - Title Company Dollar Limits (Chapter 284-29 WAC)
George Peters
execdirector at washingtonlandtitle.com
Wed Mar 20 16:26:40 PDT 2024
TO: WLTA Members (NOTE: You may get more than one copy of this email due to
overlapping distribution lists.)
RE: Request for Regulatory Review - Title Company Dollar Limits (Chapter
284-29 WAC)
Please see (1) attached letter sent to the Office of the Insurance
Commissioner requesting a review of certain WAC provisions, and (2) a
response (below) from M. Todd Dixon of the OIC.
As you probably know, members of the WLTA are invited to participate in a
meeting with representatives of the OIC, and this question was raised at the
2023 meeting, resulting in the letter.
NOTE: We are NOT inviting any comments or discussion of this matter by or
among WLTA members via email. However, the Board may re-visit the topic at
the request of a member at a future Board meeting.
Here is Mr. Dixon's response:
Dear Mr. Peters,
Thank you for your request dated November 15, 2023 regarding title company
expenditure limit increases. The Office of the Insurance Commissioner (OIC)
reviewed the specific dollar threshold amounts for title companies
transacting business in Washington and believes they are appropriate. We
have compared our existing regulations to other states' authorities and have
determined that your request will not be added to the next rulemaking
agenda.
The Legislature delegated rulemaking authority to the OIC to limit title
insurance business inducements, and our current code reflects a focus on the
consumer protections that title insurance products provide, not on gifts and
exchanges. The statutes require our agency to ensure that title companies
and affected parties focus on the business of this industry and avoid
improper influence by exchanging other items of monetary value. Title
company expenditure dollar limits serve important consumer protection
purposes, and we believe Washington markets are best maintained by the
existing thresholds.
The OIC has continued interest in your industry goals, so we'd like to
request further information on the thresholds you prefer. We welcome you to
submit materials that support an industry need for increased limits, such as
evidence that the current limits are resulting in consumer harm or decreased
market adequacy.
Please note that this response does not constitute legal advice and that the
OIC is not in the position to provide you with legal advice on this issue.
Thanks again for your correspondence. We look forward to continued
conversations with the land title industry.
<https://urldefense.com/v3/__http:/www.insurance.wa.gov/__;!!L1aKtqoz4WY!abS
Ftb4M_zUI1nt5_Jqs7FJtYzuXLb1i8dx1F20hjNOrerjL0pugG2jj-eSR4zNsWbBQ_tyUtT9jkp8
v6yB3-g$>
M. Todd Dixon
(he/him/his)
Deputy Insurance Commissioner
Consumer Protection Division &
Agency Tribal Liaison
Washington State Office of the Insurance Commissioner
360.725.7262 / office
1-800-562-6900 (Hotline)
Todd.Dixon at oic.wa.go <mailto:Todd.Dixon at oic.wa.go>
George
George Peters, WTP
Executive Director
Washington Land Title Association
<https://washingtonlandtitle.com> https://washingtonlandtitle.com
Mail: PO Box 328, Lynnwood, WA 98046
Delivery: 6817 208th St SW, #328, Lynnwood, WA 98036
206-437-5869 (Mobile)
206-260-4731 (Fax)
<mailto:execdirector at wltaonline.org> execdirector at washingtonlandtitle.com
This is a confidential communication intended solely for the named
recipient. If you are not the intended recipient, please destroy it and call
George Peters at 206-437-5869 immediately. Thank you.
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