ComplianceĀ You Can Prove
Governance, risk, and compliance services for titleĀ and escrow agencies, and other organizations that handle sensitive customer information
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The ChallengeĀ
Your underwriter agreement requires you to safeguard customer information under the Gramm-Leach-Bliley Act and to keep documentation proving you do. The FTC Safeguards Rule (16 CFR Part 314) spells out exactly what that program must contain, and since May 2024 it requires breach notification to the FTC. When an examiner, auditor, or underwriter asks for your written risk assessment, "we take security seriously" is the wrong answer.
Farris Consulting Group builds the program, the paperwork, and the habits that produce the right answer.
Services
Risk Assessments. A written, examiner-ready risk assessment built on your actual operations: data inventory, asset inventory, threat identification, scored risk register, and a prioritized remediation plan. The document the FTC and your underwriter ask for first.
Written Information Security Programs (WISP). Development of a comprehensive written security program mapped to every element of 16 CFR 314.4, from Qualified Individual governance through breach notification. Policies written for how your office works, so you can follow what you sign.
Incident Response Planning. A written incident response plan tailored to your operation, with roles, communications, and escalation paths defined before you need them. Includes tabletop exercises built around the scenarios that hit this industry: wire fraud, business email compromise, and ransomware.
Settlement Service Provider Compliance. Compliance support built specifically for title and escrow operations, informed by underwriter agency agreements, ALTA Best Practices, and the realities of wire-heavy workflows.
HIPAA Regulatory Compliance. Risk analysis and safeguards documentation for organizations handling protected health information.
Why FCG
Farris Consulting Group works at the intersection of compliance, security, and investigations. We have seen how these programs fail, how examiners test them, and how fraud exploits the gaps. That experience shapes every document we produce: practical, specific to your operation, and defensible under scrutiny.
Ready for a program you can show to an examiner?
Request a consultation and we will scope the work in one call.
