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Utterly Disappointed!
by Robert Franco | 2009/09/08 |

I dropped my membership in ALTA several years ago, but I hadn't completely given up hope on the organization.  I have been watching them to see if they could make me change my mind.  Unfortunately, they have not.  In fact, just the opposite... I am much less likely to re-join now than ever before. 

It appears that ALTA gave up on trying to reinvent itself and show us all that it could represent the small, independent agents along side the underwriters and large agencies.  Rather, they have decided to license the ALTA forms that we all need to conduct our business.  Surely, this is a blatant attempt to get money from agents after they have completely failed to give them any real reason to join. 

Source of Title Blog ::

First, let me highlight a few of the reasons that caused me to cancel my membership in ALTA.  It basically boils down to two things: 1) I felt that they were not representing my interests as an independent title agent; and, 2) they seemed to be more in the business of soliciting me than representing me. 

On the representation issue, there is an inherent conflict of interest between the big underwriters and agents, and the small, independent agents.  It seems to me that ALTA either stands with the large companies that line its pockets or they duck the issues that small agents really care about. There are a few areas where those interests overlap, such as RESPA reform, but even there it only goes so far.

As a small agent, the issues that I care about the most, and where I need the representation of a national association, are the ones that seem to slip through ALTA's fingers.  For years, this industry has been giving away profits to Realtors, lenders, and builders through Affiliated Business Arrangements ("AfBAs") and ALTA has blindly accepted the practice. 

The underwriters have largely embraced AfBAs because it allows them, or their largest agents, to capture referral sources and lock out competitors.  They get the same split of the premium whether it comes from an independent agent or an AfBA.  Meanwhile, small agents are being excluded from more and more of the market.  Where was ALTA as the small agents suffered?

Similarly, a few years ago there was an "off-shoring" craze that hit the title industry.  Orders that used to get handled by local title professionals are now being done in India and the Philippines.  What did ALTA do?  ALTA began incorporating off-shoring segments at their conferences.  They embraced the practice as local title professionals saw work leaving the country to boost the profits of ALTA's largest members. 

In 2007, when I wrote the blog about ALTA's position on off-shoring, I checked its directory to see who the members were in my county.  Surprisingly, they were overwhelming small, independent title professionals.

What is most perplexing to me is the make-up of the ALTA membership. I checked their online directory to see what their membership looked like in my home county. There are seven ALTA members here: six are single-person, independent abstractors and one is a title agency. Of the three large title agencies in town, only one is listed. There are four small independent title agencies here and none of them are listed as members. We no longer have any of the large direct operations in town.

The conclusion that I drew was that ALTA did not really represent the majority in terms of numbers, it represented the majority in terms of dollars of dues paid.  Since I was never going to be in the latter category, I saw no representation from ALTA that made me want to be a member.

So, what other benefits did ALTA offer?  Well, there was the opportunity to acquire E&O insurance through ALTA's risk retention group, TIAC.  But, once I priced insurance through a traditional insurer, I found that I was able to get a lower premium elsewhere.  This was surely not a reason to pay dues to ALTA when I wasn't getting the representation I wanted.

ALTA also offers various educational and marketing materials.  I have purchased a few items in the past but I largely found them to be very expensive for a small agent.  And, it seemed that I was solicited to purchase them quite frequently. 

I hear that ALTA does put on a great conference, several of them actually.  Unfortunately, they too are very expensive. The 2009 ALTA Annual Convention is $850 for members ($1,400 for non-members) and when you look at the topics they have covered in the past, you really have to wonder if they even had the independent title professional in mind.

The 2007 ALTA Tech Forum listed abstractors, searchers and examiners among those who should attend.  But, take a look at some of the event sponsors:

GATORS® Unit of Fiserv Lending Solutions Introduces On-line Title Abstracting Tool:
"GatorSearch provides GATORS users the ability to execute self-service title searches, greatly reducing the turnaround times associated with traditional examiner/courthouse abstracting. Reports can be run from the office or home computer to provide searches that are fast, comprehensive, reliable and precise."

"NextAce is expanding its automated title software and services offering, Title EDGE®, to deliver full resale and long-form commitments. By automating the resale process, the consumer can benefit from a faster settlement, title insurers can deliver a faster and more consistent product while reducing their associated production costs, and lenders realize process improvement and faster application-to-close turn time.

NextAce has led the title technology charge to service both large and small title insurers with Title EDGE. Founded in 2003, NextAce has processed over 300,000 preliminary title reports and commitments, and is delivering on more than 80 percent of submitted orders. Title EDGE is the nation's leading automated title examination and report generation product".

String Real Estate Information Services:
"Online title examination current owner to chain of title and all varieties of searches in-between using online county plants and private sources."

Also from String Real Estate Information Services, Outsourcing Decision Has Benefits, Challenges:
"Another benefit of off-shoring results in (sic) a 24/7 processing. Since most of the outsourcing does go to India, many processes can be completed overnight, allowing U.S. businesses come back the next day with a day's work completed.

The more obvious benefits include lower labor cost. However, there is also the possibility of obtaining additional services."

Perhaps what they were really saying to the abstractors, searchers and examiners was "come and meet the folks that are going to put you out of business."  Hardly an event I want to pay to attend. (see Lose Your Job And Win a High Definition TV!).

But, as I said, I hadn't completely given up hope on ALTA, largely due to one man - Mike Pryor, ALTA's current President.  Mike seemed to understand the plight of the little guy.  He wanted to reach out to small agents and title abstractors.  When I first found out Mike was going to be taking the helm at ALTA, I wrote a blog about him.  (see I Like Mike).

Just when it seemed to me that the traditional title insurance industry was giving up on thorough searches, Mike wrote about the importance of the title search.  (see Mike's Email).

Oh, I know, we can argue all day about how good is good enough, but unfortunately, we as an industry, have spent too much time arguing about how good a search should be before issuing a title policy when we SHOULD be discussing how good a search is necessary to satisfy our duty to our customers.

Finally, someone seemed to "get it," and he was going to be the President of ALTA!  I knew he would have an uphill battle in an industry dominated by the "short-search" and "off-shoring" mentality, but I had hope.  I was skeptically optimistic.

I wished Mike luck and I told him that if ALTA could show me that it was going to represent my interests, I would re-join in a heartbeat. 

Well... apparently, having a traditional title agent at the helm of ALTA just wasn't enough.  Nothing changed... except ALTA's new plan to charge a licensing fee for ALTA forms.  I find this despicable, deplorable, degrading, and, for lack of another word that begins with "d," offensive!

ALTA forms have become the standard in the title industry.  Title agents are required to issue ALTA policies and endorsements.  What choice will agents have but to pony up the money and pay ALTA's ransom? None at all... This much, ALTA knows.

"ALTA's uniform policy forms have become the 'gold standard' throughout the lending and legal communities. Because land title insurance coverage is standardized, the secondary market readily accepts mortgages that carry title insurance. This has greatly contributed to the growth of demand for title insurance across the country," said Mike Pryor, president of ALTA.


"Licensing of the policy forms will reduce the drain of critical resources to the association and protect the value of ALTA forms far into the future. "ALTA is doing more than ever to carry the banner for our industry. We want to keep up that level of advocacy on behalf of our members and for all in the title business. And, we want to do it in an environment where all beneficiaries share in the cost," Pryor continued.

The problem here is simple... ALTA does not advocate for "all in the title business."  And, as a result, many have chosen not to join and support an organization that does not represent them or, more bluntly, an organization that seems content to see them go out of business.

ALTA could have chosen to direct more energy to representing the independent agents.  It could have chosen to give them a reason to join voluntarily.  But, it did not.  It didn't float this idea for public comment from the masses of independent agents who have stayed away from ALTA.  It didn't ask what it could do to help the independent agents.  It simply said "support us, or get out of the business."

ALTA knows what troubles the independent agents face.  If it doesn't, it has had its head buried in the sand deeper than I thought.  Does ALTA think that forcing unwilling agents to fork over money to an organization they do not want to support is going to place them in a better light with those agents?  No.  It just doesn't care.

As a small agent, I am operating in an environment where I can't compete.  The industry is experiencing a severe recession. AfBAs, many of them shams, have prevented me from accessing many referral sources for what work remains. Ohio now requires an expensive independent audit by a CPA every year.  Work we used to do is now being outsourced to foreign countries.  Remaining in business is a constant struggle and ALTA's response is to tell me that I have to pay them a licensing fee to do what little work I can manage to find.  How does that help me?

This is just a shame.  Mike said that "this program will be a small step toward reestablishing a level playing field for all industry participants."  What Mike fails to realize is that it is precisely because ALTA has NOT advocated for a level playing field that I have chosen not to support it.  Let me state in no uncertain terms that I am not interested in helping the industry maintain a playing field if they aren't going to fight for my right to play in the game.

Utterly disappointed,

Robert A. Franco


Categories: Abstractors, Land Title Associations, Small Agents

2770 words | 5447 views | 17 comments | log in or register to post a comment

Indifference or Ignorance?


Reading the press release put out by ALTA, I can't understand whether the decision to charge the fee was based on indifference to the plight of indy title agents and examiners or ignorance to the same. 

Unlike a copyright action between the RIAA and college kids who are supposedly downloading songs for free, ALTA will be left in the unenviable position of "enforcing" its license against the very same people it hopes to gain as members and supposedly serves as the "voice" of the title insurance industry.

Their decision is remarkably short-sighted and foolhardy.

I'll say it again.  When you believe you stand for everything and everyone, there really isn't much that you can truly stand for.

This decision is just another cog in that wheel.

by Robert Holman | 2009/09/08 | log in or register to post a reply

Interesting analogy...

It will be very ironic when ALTA has to enforce its licensing fee against an independent agent that it claims to care so much about.  However, I don't want it to be me.  Didn't the RIAA get a $1.9 Million judgment against a Minnesota mom for downloading copyrighted music? I don't want to be the shining example of the new "agent-centric" ALTA. 

I just wish there was another option - ALTA has a monopoly on those forms.  I'd rather pay someone else twice as much than give a dime to ALTA.  As it is, I'll really have to think about whether it is worth it for me to remain a licensed agent.  I haven't done much while I have been in law school and the market is pretty scary around here.  Between the sham AfBAs that nobody seems willing to do anything about (except the OAITA, of course) and the expenses of audits, new software, RESPA reform, insurance, etc., there just isn't much reason to stay in the game.


by Robert Franco | 2009/09/08 | log in or register to post a reply

Copyright Laws

I'm not well-versed in copyright law, but it seems to me that ALTA may have issues in enforcing the fees and suing for financial loss. After all, they have freely disseminated these forms for several decades, now, without requiring a contract or payment.  Also, is there an expiration date for copyrights?  I'm sure they have paid their attorneys well (with your dues money) to research the legal ramifications of enforcing the copyrights against title agents.  I would love to learn more about the time/dissemination issue as it relates to copyright laws.

by J. H. | 2009/09/08 | log in or register to post a reply

Your Greatest Competitor is your underwriter!


Robert -- you're a breath of fresh air!
ALTA is a sounding board for the underwriters. It always has been and will continue to be. Anyone who believes small independent agents have a voice in ALTA will also believe in the tooth fairy! ALTA only promotes underwriter interests and they will undercut and subvert any voice in the organization which attempts to refashion those designs.
It is unfortunate agents don't have a stronger voice and organization which would counter some of the most egregious practices by the underwriters. And this affects their business and profits greatly. Remember, 60 percent of underwriter income derives from small independent agents!
Since 1999 First American has paid nearly $70,000,000.00 in fines for RESPA and insurance violations. Fidelity has paid over $21,000,000.00. If you throw in the other fines by the smaller underwriters it's over $100,000,000.00 in fines!! And there's probably more - I didn't research all of it. That's ONE HUNDRED MILLION!! And the underwriters will yell all day the unfairness of title insurance premium scrutiny. Can you believe it?
I would just like to know the total defalcation claims paid vs. the fines. I'll bet the underwriters paid more in fines.
It's a disgrace!
The real difficulty is agents who voice any objections simply have their contracts cancelled. It's simple enough for the underwriters to control.
First American, in one example, was ordered by the Florida Department of Insurance to close 87 (that's eighty seven) sham title agencies. They were doing nothing but funneling premium dollars back to the referrer. "The entities enlisted real estate agents, mortgage brokers, banks and homebuilders who referred business to First American's sham title insurance agencies, resulting in unfair financial gains to First American and its affiliated title insurance agencies", the State of Florida said.
Examine the ALTA web site and see what comments or opinions exist with regards to this kind of behavior! NONE!!
Imagine how much business and profits have been removed from the coffers of honest agents by these underwriter tactics! And agents have no choice but to send their remittances while the underwriters are conducting this great rotor-rooter job!!
It must be extremely denigrating to send money to the one who undermines the fairness of the game. In most other industries the manufacturer bends over backwards to protect the integrity of its independents.
The only way to get business back to competitive fairness is to remove the insured closing letter. But I'll bet we're going to see an extension of this phenomena. Underwriters will guarantee lenders against "tolerance" deviations with the new RESPA regulations beginning January 1st, 2010.
By the way, it would seem impossible that anyone could "copyright" insurance coverages. Wouldn't this be tantamount in attempting to license contracts of sale and other like instruments of real estate?
by Wyatt Bell | 2009/09/08 | log in or register to post a reply

La Cosa Title

Even funnier from ALTA's FAQ on the new program:

"This initiative was first discussed by independent title agents who felt new agents were not paying their fair share, and believed this would help level the playing field."

Independent agents have no reason to join ALTA, so they are basically saying that agents who weren't members were complaining that other agents were also not members.  And how does a $200 nuisance fee "level the playing field" in an industry where underwriters compete with agents and the emphasis is getting the cheapest search and then spreading out the losses those generate on all consumers by upping the premiums every few years?

An association implies freedom to join or leave membership.  They are now using state regulations that mandate the use of their forms to force everyone to join (or is membership just an added bonus for paying the licensing fees?)  Maybe they should change their name to the American Land Title Compulsion or La Cosa Title.

by David Jenkins | 2009/09/08 | log in or register to post a reply

Thanks, David...

Thank you for the link to the Pennsylvania Land Title Association site with the FAQ about the licensing program.  I found it quite interesting that "subsidiary companies" are covered under their parent companies.  A subsidiary is defined by ALTA as "over 50% of your company is owned by a parent company who is an ALTA member."  This basically means that ALTA is including all of the AfBA's owned by a larger agency or underwriter under the main partner's membership or ONE licensing fee. 

After all, the main partner in the AfBA usually owns 51% of the company.  It is good to know that ALTA is looking out for the small agent by not burdening the big companies with several of these AfBAs - many of them shams (heavy sarcasm, there).  How is ALTA "leveling the playing field" when it charges independent agents licensing fees, but it doesn't charge all of the "separate entities" created for the sole purpose of funneling profits to referrers (and locking the independent agents out of the market)?

This is a shining example of how ALTA is not really interested in a level playing field - they just want to get the independent agents to pay them for their efforts to tilt the board in favor of their largest members... once again.

by Robert Franco | 2009/09/09 | log in or register to post a reply

I'm not saying I disagree, but...

I disagree.  I have put up a post on my blog that explains why I think this initiative can and will be a good thing for our industry.  The bottom line might be dollars and cents, but I believe that this can have a positive and lasting impact outside of the added revenue. Friendly disagreement is the cornerstone of a healthy democracy! 

Thank you!
Michael Rubin


by Michael Rubin | 2009/09/10 | log in or register to post a reply


If I may sum up your blog post in a sentence, your sole argument for the ALTA licensing initiative is that it will "force" industry participants to "speak up", which will be beneficial since the leaders of the land title associations are not "mind readers". 

I would suggest that Robert has spoken up and that there is no need for anyone involved to be a mind reader to know what his concerns about the industry are.  It's not a communication problem; it's a conflict of interest problem.  For instance, when Robert aksed the Ohio Land Title Association to look into the legality of AfBAs in the state after a case had been brought before the Supreme Court on the issue, the association punted, explicitly citing the fact that some of its members might not be in support of the case as a justification for its inaction.  Ironic, because OLTA has weighed in in support of AfBAs in the past even though its membership was not of one mind on the subject.  It certainly appears that there's a double-standard here:  for the association to even look into an issue that might negatively affect a big money member, unanimity of the membership is required; to offer opinions that are essentially hostile to the interests of small independent members, no such unanimity is required. 

by Slade Smith | 2009/09/10 | log in or register to post a reply

Michael, there is always room for disagreement...

But, you are at a different stage in your relationship with ALTA than I am.  I have been there.  I was a member and I filled out their surveys and let them know what issues I was facing as an independent agent.  This went on for years and when they failed to show any interest in representing my interests (of which I think I have provided some examples), I chose to leave the association.

Much like Slade said, nobody expected anyone at ALTA to read minds.  At every conference I have been to I have overheard agents lamenting about the affects of AfBAs on their business. It hasn't been a secret... independent agents have been very vocal.  Maybe they weren't all ALTA members, but I was and I voiced my concerns.  Earlier this year, I spoke with Mike Pryor and I told him exactly why I dropped my membership. I even told him what it would take to get me back in the fold. 

You stated that "Our state Land Title Association’s are the backbones of ALTA. We are the support structures that give ALTA its strength to tackle the issues that affect us all."  But, the point you are missing is that ALTA isn't interesting in tackling the issues that really affect the small, independent agents.  This is most apparent when you look at who ALTA is targeting with its licensing fee... it isn't the AfBAs, they won't have to pay it because they are covered under their parent company's membership.  Once again, they are providing a huge benefit to the AfBAs at the expense of the independent agents.

You apparently believe that "the most glaring problem with ALTA is its lack of interested parties," but I would have to disagree with you there.  The masses of independent agents are interested, they just aren't interested in the vision of the industry promoted by ALTA.  I am a member of the Ohio Land Title Association and the Ohio Association of Independent Title Agents.  I am willing to join an association that I believe in... I just don't believe in ALTA.  Rather than attempt to give me a reason to join and support them, they have chosen to further alienate me by forcing me to support them in order to write title insurance in Ohio, by licensing their forms (on which they have a monopoly).

It is great that you have "gotten involved," and it is great that you had that choice.  The rest of us no longer have a choice in that matter and that is a real shame.  If ALTA can force independent agents to support them financially (and apparently they can), what incentive do they have to listen to their concerns?  They never have before, why should I believe that they will start now?

by Robert Franco | 2009/09/10 | log in or register to post a reply

I just don't see it...

I am more than willing to accept yours and the other opinions expressed.  I just don't understand it.  That's fine, I don't have to understand it.  You seem to carry a venom for ALTA that just befuddles me.  Fair enough, we all have our own viewpoints and different agendas that carry different meaning for us all.  I don't like AfBA's, but this isn't my main concern.  If it is yours and ALTA doesn't step up to the plate enough for you, you do have the right to not be a member.  It is my belief that AfBA's are more of a state issue, and should be handled with your state title association and state governing body.  Anyway... This is an interesting debate and it certainly points out that all Title Insurance is local. 

by Michael Rubin | 2009/09/11 | log in or register to post a reply


AfBAs are a state AND federal issue... it started as a federal issue and the states are following along.  The federal government carved out exceptions in Section 8 of RESPA just for AfBAs.  Until then, the state prohibited them. And, the Gramm Leach Bliley Act specifically permits banks to sell insurance. 

No state may, by statute, regulation, order, interpretation, or other action, prevent or significantly interfere with the ability of a depository, or an affiliate thereof, to engage, directly or indirectly, either by itself or in conjunction with an affiliate or any other person, in any insurance sales, solicitation, or crossmarketing activity.

This is clearly a federal issue.  Although I believe that the states still have the right to prevent AfBAs in title insurance, they have not been inclined to do so. 

It is not "venom" I have for ALTA.  ALTA is free to do as it pleases.  I just have no desire to support an organization that does not advocate for small independent agents.  For the past few years, I have not supported ALTA and I was fine with that.  My problem now is that I don't have that choice anymore.  ALTA is going to charge small independent agents this licensing fee regardless of whether or not we support their initiatives.  Meanwhile, the AfBAs which benefit from their representation the most will not have to pay it.

And, it isn't just the AfBA issue.  They have clearly shown that they are only interested in furthering the objectives of their largest members.  They have embraced off-shoring, they have done nothing to curb the declining search standards in the industry, and they seem unwilling to take any position that favors the independent agents when it conflicts with the profit motives of their largest members.

If ALTA doesn't want to represent me, I'm fine with that... so long as they don't force me to help pay for their representation of the underwriters. And, that is basically what this licensing fee is aimed at doing.

ALTA could have chosen to give me, and the many other independent agents, a reason to join... but, they haven't.  As I said in my blog, I am disappointed in ALTA. 

by Robert Franco | 2009/09/12 | log in or register to post a reply


Rather than bickering, why don't we put our energy toward coming up with a solution.  How about some brainstorming?

For example, might it be possible to work with State Departments of Insurance to get state forms created and mandated?

Or forms issued by the underwriters?

I really don't know, but there must be something we can do.

by Cheryl Hartzman | 2009/09/14 | log in or register to post a reply

Take Action

I have personally contacted the National Association of Independant Land Title Agents (NAILTA) today, as well as my state attorney General (PA).  Our attorney general is hell bent getting rid of ABAs in our state, cleaning up the corruption, and reducing the cost to consumers, he'll be interested in this.  Not to mention, ALTAs position could be seen as a monoply or violating their status as a Non-Profit.  Next will be letters to my state and US Congress people and the Department of Insurance.

I encourage each of you to do the same.  Take a consumer friendly stance, rather than self serving when contacting these people.

by Cheryl Hartzman | 2009/09/14 | log in or register to post a reply

Excellent idea...

There are organizations out there who DO advocate for the independent agents and worthy of our support.  NAILTA is a great choice!

I don't know that there is much hope for getting different forms apporved - such an initiative would most likely have to come from an underwriter.  Seeing as how we didn't hear anything from them until after ALTA announced their licensing plan (come to think of it, we still haven't heard anything from them), I don't think they will be interested in reinveting the wheel.

I also have to wonder if our state land title associations knew anything about this travesty.  Did ALTA even share their plans with them?  I hope not - otherwise, it seems awful sneaky of them to keep us all in the dark on the matter.  You would think that an industry-wide change like this would have at least warranted a heads-up.

by Robert Franco | 2009/09/14 | log in or register to post a reply

TIAC Renewal

I have never liked having to co-mingle the TIAC fees with my E&O and they have both disregarded me.  I went to an ALTA Convention in 2002 with nothing to offer the little guy.  TIAC has more than doubled my rates with no claims after 7 years of insuring me to offset them taking on higher risk offshore competitors to limit my business.  Time for renewal next month...looks like I should look elsewhere.  Any suggestions?  Let's push for regulating Abstractors.  The premiums are up because they pushed off-shoring in a business that is difficult enough when you know the ins and outs.  The title starts with the Abstractor and if you don't hire a quality abstractor, the whole industry suffers. 

by Angela Swafford | 2009/09/14 | log in or register to post a reply

Regulating abstractors...

I have often advocated regulating the abstractors.  The title search is the foundation for every title insurance policy.  Without a good search by a knowledgeable abstractor, the most thorough exam by the most qualified title insurance agent, underwritten by the highest rated underwriter is worthless.  Consumers can spend thousands of dollars on title insurance and the title companies are writing policies on $40 searches performed by anyone with a pen and a fax machine.  Worse yet, some are being done for less than $5 by someone in India with access to an incomplete database of online records.  Nobody seems to care.

I have advocated for laws that would require a search conducted and certified by a licensed abstractor before any title policy could be issued.  The problem is, of course, that it would cost more money and the traditional title industry will never support it.  The state land title associations and ALTA would probably fight it, and they would certainly be asked to provide comment to the General Assembly on the issue. 

Ohio recently changed the foreclosure procedures to require, in most cases, a title policy.  The industry supported that because it meant more money for them.  Ironically, however, they specifically allowed the policy to be issued on a short search, which of course costs the title companies less money.  It makes you wonder who writes the laws?

by Robert Franco | 2009/09/15 | log in or register to post a reply

State Mandated Forms

(Angela, try State Farm for your E&O, they are highly competitive.)

I'm in Pennsylvania and here the use of ALTA's policy forms are state mandated.  I suspect the same is true for most states.  Honestly, I don't see how a state can mandate the use of forms when a licensing fee for those forms is charged by a private lobbying group.  That's bad politics.

Not to mention, as state revenues drop, each Department of Insurance could institute their own forms and charge their own licensing fees for them as a new stream of revenue.  If I have to pay a fee, I'd rather it go to my state then to a private entity with whom I may or may not agree with.

by Cheryl Hartzman | 2009/09/15 | log in or register to post a reply
Source of Title Blog

Robert A. FrancoThe focus of this blog will be on sharing my thoughts and concerns related to the small title agents and abstractors. The industry has changed dramatically over the past ten years and I believe that we are just seeing the beginning. As the evolution continues, what will become of the many small independent title professionals who have long been the cornerstone of the industry?

Robert A. Franco



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