Join  |  Login  |   Cart    

Notary Rotary
Some insights on GLBA practices 'inside'
Notary Discussion History
 
Some insights on GLBA practices 'inside'
Go Back to June, 2011 Index
 
 

Posted by ReneeK_MI on 6/27/11 8:18am
Msg #387796

Some insights on GLBA practices 'inside'

I am of the opinion that non-compliance with the GLBA, as it flows from lender through the services of contract closers/witness-only signers, is at the top of the list of ways our industry could implode overnight. The entire GLBA is 145 pages long and appears to be written in an alien language, and while I might wish everyone would read & heed, perhaps that's just not practical or even reasonable. As an alternative learning tool, I thought I'd share some of the protocols that were followed in the last lender's office where I worked - and I note that most of these same protocols are followed within the walls of title companies I've worked inside as a contract closer.

To set the stage, I worked for a wholesale lender, and there is almost NO non-employee foot-traffic into a wholesale office - other than the couriers, the risk of anyone viewing something they shouldn't see was almost non-existent. Still ...

* The front reception desk was isolated from the 'inside' office by a locked door opened via individual employee passcode. Two people were stationed in reception (since they were so isolated, the 'buddy system' was used). Their computers were separated from the internal network, and had no access to internal, secure software. We were once fined because one of the 2 people was sick, we were too busy to spare a 'buddy', and the sole receptionist had to run to the bathroom - so she propped that locked door OPEN (so if someone did come in, the inside office could hear the entrance door buzzer & greet). Guess who stopped by at that moment? The Feds. That door being propped open & no person there = 'unsecured' private data.

*Every piece of waste paper, even if it was BLANK, went into locked shred-bins. (If you've never seen one, the only opening is like a mail-slot.) If you accidentally tossed something, there were only 2 people with keys, and one of them would have to unlock it and STAND THERE while you retrieved your piece of paper. Once a week, the secure shred service arrived and one of those two people had to personally accompany each load out to the shred-truck, and WITNESS the shredding.

*Every monitor had a privacy screen - no chance of glancing at your screen from the side of your desk! All were on 60-second timeout into the secure system - you kept working & fast, or you were logged out. 30-sec timeout for screen-saver. 30-day passcodes, and after a few years ...that gets tedious. All monitors faced away from the common areas. These 3 security protocols together had a huge impact on you, when you're short of time and have to BOLT for a printer or a phone and AUGH, logged-out for the 300th time that day.

*Files were not to be left open if you left your desk. Like your job? You didn't forget. Did it happen? HE77 yes, think about it - your coworker says "Hey, is this good?" and you step over 5 feet to look at something on her desk, leaving your own file open ...

*NOBODY was allowed inside that office, other than employees. No pizza delivery guys, no husbands, no brokers who were your clients, NOBODY. Those that had to (like the shredder guy, or copier servicer) had to be accompanied the entire time.

*NO direct-to-borrower contact could be made for any reason, until AFTER closing. Until they signed, there exists no customer relationship w/lender and effectively, they didn't exist to us. Yes, that does make some work harder, yes it makes things take longer, yes it seems impractical - yes, the GLBA is taken seriously.

*ALL employees were background checked AND drug-tested AND fingerprinted.

*Closing docs were placed on a secured website for download ONLY to be downloaded by an approved (insert a lot more protocol here) Settlement Agent ONLY after a valid, signed CPL was in each file. Period. That secure system & protocol wasn't cheap, and WAS quite the PITA. GLBA. Whatever the Settlement Agent did after D/L is entirely on them to secure & be held liable for.

I could go on and on, but I'm hoping the point is made - there are so many ways that implementing the GLBA is so impractical that it almost impedes workflow, almost unreasonable in the course of doing a job, but it is SO CRITICAL and CRUCIAL to absolutely secure people's private information. You work in those environments long enough and thinking about security becomes second-nature, it is PART of the job.

I do realize not everyone has GLBA stamped across their forebrain, but so many common practices I read about here just have me aghast, and feed my notion of an overnight implosion. All it takes is ONE bad choice to hit the media. If I saw you go inside a lender's office and try to take a picture of someone's ID with your cellphone, I think I'd hide under a desk waiting for all kinds of he77 to rain down. Does the Settlement Agent or anyone else care how YOU make your own little self liable? Disclosing people's names, loan numbers, forwarding e-mails, leaving info on voice-mails, contacting borrowers for someone else's debts, all this just blows my little GLBA-imprinted mind.


Reply by Claudine Osborne on 6/27/11 8:42am
Msg #387798

Renee, Thanks for the info from the inside. It is really mindboggling what people will do with bo info..I cant believe the notary from another post did what she did..I can't seem to understand why she did this?

Does she and everyone else realize that the TC, SS and Lenders etc read this board? I would never hire someone that has committed such a serious offense!

Reply by MW/VA on 6/27/11 9:04am
Msg #387804

Thanks, Renee. While this sounds very extreme, I can sort

of understand the cos. position regarding it's liability if an employee used any info for wrongful purposes, including the risk of identity theft. The gov. & military operate that way, with encrypted info. I think the question of the century is whether info. can ever be totally secure?
BTW, I worked for one of the tax prep firms a few years ago. They hired anybody & everybody. There were no bgc's, etc. Since they paid bare minimum wage, it was a prime spot for someone to place themselves in who wanted to gain access to personal info. After all, in tax prep they have it all, names, addresses, ss #s, employers, etc. I found it shocking to say the least.

Reply by parkerc/ME on 6/27/11 10:26am
Msg #387815

Excellent example, Renee. Although implementing the level of all these controls would not be feasible for us as independent contractors, it boils down to . . . (1) what are the risks at each stage of our processes (risk assessment) and (2) what controls can we put in place to eliminate or minimize those risks. And the most blatant risk illustrated by the post below, is the unauthorized disclosure of that personal information by the notary/signing agent. Thanks, Renee!


 
Find a Notary  Notary Supplies  Terms  Privacy Statement  Help/FAQ  About  Contact Us  Archive  NRI Insurance Services
 
Notary Rotary® is a trademark of Notary Rotary, Inc. Copyright © 2002-2013, Notary Rotary, Inc.  All rights reserved.
500 New York Ave, Des Moines, IA 50313.