Town n’ Country Title prides itself on providing quality products and service to its many customers. The American Land Title Association’s (ALTA’s) Title Insurance and Settlement Company Best Practices are a way for our team to demonstrate its commitment to our goal of striving to always improve upon what we do, and to earn the trust of those with whom we do business. We look forward to a continued working relationship and want to thank you for your business.
ALTA ID: 1065381
BEST PRACTICE NO. 1 – LICENSING
Establish and maintain current license(s) as required to conduct the business of title insurance and settlement services.
TOWN N’ COUNTRY TITLE, LLC – POLICY NO. 1
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls related to maintaining current licenses as required to conduct the business of title insurance and settlement services in the State of Wisconsin.
1.01 REQUIRED LICENSES AND REGISTRATIONS
As a current and active member of the American Land Title Association (ATLA),Town n’ Country Title, LLC also maintains those licenses as required by ALTA’s Policy Forms Licensing requirements. A copy of the current TNCT membership certificate for ALTA is available upon request.
All annual reports and fees, as required by the Wisconsin Department of Financial Institutions & the Minnesota Department of Financial Institutions, are also tracked for compliance to ensure they are submitted on an annual basis.
REVIEW OF LICENSING REQUIREMENTS
Town n’ Country Title, LLC obtains materials regarding licensing requirements from a variety of sources.
Information on the status of the LLC, as a business entity, is retrieved from the Wisconsin Department of Financial Institutions’ website.
Also, the Wisconsin Land Title Association (WLTA) & Minnesota Land Title Association (MLTA) disseminates information on licensing to its members.
Lastly, Town n’ Country Title, LLC receives information on licensing requirements from its underwriters, First American Title Insurance Company, Old Republic National Title Insurance Company, and Alliant National Title Insurance Company. TNCT is in good standing with each of its underwriters. A letter of good standing can be furnished upon request.
No continuing education is required to maintain a Wisconsin or Minnesota Intermediary License.
All TNCT employees who are performing the functions of an intermediary in Wisconsin and/or Minnesota are required by the company to be licensed. These employees shall hold the respective states Intermediary’s License as issued by the Wisconsin Department of Insurance or Minnesota Department of Commerce.
If a person is hired by TNCT who should be but does not currently hold the appropriate Intermediary’s license, that person shall be required to become licensed within a reasonable time after their initial date of employment.
A listing of all TNCT’s currently licensed employees is included with the supporting documentation for Pillar #1.
A list of individuals holding a Wisconsin or Minnesota Intermediary License is submitted to TNCT’s underwriters. When a license become inactive or a person no longer is employed by TNCT, the HR Manager of TNCT notifies the applicable underwriters.
Town n’ Country Title, LLC maintains both an electronic and hard copy of current licensing information. The hard copy is kept in the appropriate employee file. The electronic copy of this licensing log is kept on the TNCT network in a folder.
Each month the HR Manager reviews the electronic and hard copies of the current licensing information to determine which licenses are expiring in the subsequent month.
One month prior to the expiration of the license, the HR Manager notifies the employee as a reminder for them to renew their license.
ACCESS TO LICENSE INFORMATION
For security purposes the hard copy of licensing information is kept in the office of the HR Manager. Only the Owner/President and HR Manager shall have access to this information.
The electronic spreadsheet tracking license information shall be kept by the HR Manager.
BEST PRACTICE NO. 2 - ESCROW TRUST ACCOUNTING
Adopt and maintain appropriate written procedures and controls for Escrow Trust Accounts allowing for electronic verification of reconciliation.
NOTE: These procedures apply to all custodial or fiduciary accounts including closing and disbursement accounts, recording accounts, construction disbursing accounts, underwriter remittance/premium accounts, and other similar accounts.
TOWN N’ COUNTRY TITLE, LLC POLICY – NO. 2
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls relating to the safeguarding of client funds and to minimize the exposure to loss of client funds.
2.01 Escrow Trust Account Controls
Complete background checks performed as part of the hiring process and repeated every three years thereafter for all employees who have access to customer funds per underwriters’ requirements.
ESCROW FUNDS AND OPERATING ACCOUNTS ARE SEPARATELY MAINTAINED
Town n’ Country Title, LLC maintains one Escrow Account for real estate and mortgage loan transactions. These funds are held under a fiduciary capacity and are not commingled with TNCT’s operating funds or an employee or manager’s personal account. Funds are to be deposited the date received and posted in Softpro Select.
ESCROW ACCOUNTS TRIAL BALANCE REPORTS
A trial balance report depicting the balance of a particular customer’s funds can be produced for each escrow account at any time. This report depicts all individual customer file balances that do not have a zero balance. On a monthly basis, the Owner/President reconciles the trial balance report to the bank balance and reconciled book balance, creating a “three way” reconciliation. Trial balance reports are produced for each escrow account maintained by TNCT, including recording accounts and underwriter premium accounts.
ESCROW ACCOUNTS ARE PROPERLY LABELED AND MAINTAINED IN INSURED
Escrow bank accounts are appropriately designated as “escrow” accounts. This designation is noted in the original banking agreements as well as on our check stock, deposit slips, and bank statements. Escrow accounts are maintained with insured financial institutions.
DORMANT FILE BALANCES
Customer files that continue to hold funds after the settlement date are reviewed periodically to determine if any disbursements have been made. The President/Owner or a Branch Manager’s approval is required for any disbursement from an inactive escrow. An inactive escrow is defined as any escrow which has had no activity for the past six months. This approval is documented and maintained.
BANKING TRANSACTIONS CONDUCTED BY AUTHORIZED EMPLOYEES
Per agreements with financial institutions, The Company management authorizes employees for escrow bank account transactions. Wire transfer initiation and approval levels are set by TNCT and reviewed for changes in staff routinely. Former employees are immediately deleted as signatories and authorized wire transfer individuals. A list of authorized individuals is maintained in Town n’ Country Title’s Escrow Account Information Report. The individual(s) designated as the ‘wire transfer administrator’ to set-up and change online banking permissions has been authorized by Corporate Management.
Authorized check signers and wire individuals do not maintain the escrow accounting records or perform the escrow account reconciliations.
ACH blocks are used on all custodial or fiduciary accounts including closing and disbursement accounts, recording accounts, construction disbursing accounts, underwriter remittance/premium accounts, and other similar accounts
Town n’ Country Title, LLC maintains a cyber-insurance policy against the acts of those trying to unlawfully transfer funds via electronic methods. This policy is to further protect funds and to minimize the exposure to a loss of client funds. A copy of TNCT’s summary of insurance is available upon request.
2.02 Escrow Account Authorizations
Require that while one person may initiate a wire transfer, a second person must approve the wire. The funds are not debited from the agent escrow account until the wire is approved by the second person.
2.03 Account Reconciliations
Reconciliations are in an electronic format and saved electronically so we can access them in the future.
The “Positive Pay” feature will be used when provided by TNCT’s financial institution. The Owner/President reviews the positive pay exception report daily. All positive pay reports are maintained and any exceptions are documented and explained.
ACH blocks and international wire blocks, where available, are placed on all escrow accounts to prevent unauthorized users from withdrawing funds from the escrow account.
It is the responsibility of the Owner/President to reconcile the escrow accounts. Account receipts and disbursements activity are reconciled daily (two-way). Monthly, a three-way reconciliation between the bank records, book records, and trial balance is performed. This reconciliation is completed within four business days of receipt of bank statement.
A listing is kept of all escrow accounts. This listing includes underwriter premiums accounts, recording accounts and dormant accounts.
The escrow account reconciliations are available to the title insurance underwriter at any time requested.
Escrow account reconciling items are clearly noted on the reconciliations. These reconciling items are followed up and addressed by the Accounting Administrator within 4 business days of completion of the reconcilement so as to not carry over on the reconciliations from month to month.
Town n’ Country Title provides escrow account training as needed to individuals handling customer funds and conducting escrow account reconciliations. This training is conducted by the Operations Manager. All training and continuing education is tracked and maintained by the HR Manager.
BEST PRACTICE NO. 3 - PRIVACY AND INFORMATION SECURITY
Adopt and maintain a written privacy and information security program to protect Non-Public Personal Information as required by local, state, and federal law.
TOWN N’ COUNTRY TITLE, LLC POLICY – NO. 3
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls relating to the safeguarding document privacy and information for the protection of data and Non-public Personal Information (NPI).
Non-public Personal Information is described as personally identifiable data, such as information provided by a customer on a form or application, information about a customer’s transactions, or any other information about a customer that is otherwise unavailable to the general public. NPI includes first name or first initial and last name coupled with any of the following: Social Security Number, driver’s license number, state-issued ID number, credit card number, debit card number, or other financial account numbers.
3.01 Information Security (IS) Program Management
3.02 Risk Identification and Assessment
Town n’ Country Title makes an annual assessment of the standards and requirements affiliated with its information security program, including those set out in this policy and procedure document.
3.03 Employee Training, Management, and Responsibilities
Town n’ Country Title policies associated with the privacy and information security program are given to all employees and the employees must acknowledge in writing that they have read and understand such policies. There is required ongoing/continuous training on a quarterly basis for all employees.
3.04 Information Security
Individuals who have access to NPI is restricted to authorized principals and employees who have undergone a formal background check and credit report process in accordance with its underwriters’ requirements.
The use of removable media devices is prohibited unless the President/Owner, and/or HR Manager has authorized such use.
Other standard procedures for security of NPI include closing paper files other than the one currently being worked on, stow files away when away from workspace and lock desks and file cabinets at the end of the day. All computer/electronics are password protected and locked when away from desk.
Hardcopy NPI that is transmitted outside the office is done so using only by secured envelopes and/or locked document bags.
NETWORK SECURITY OF NPI
At the direction of the President/Owner, TNCT’s designated Network Administrator grants appropriate access to the various computer technology applications. Town n’ Country Title, LLC’s file server(s) is housed in a room with a secure door. TNCT’s computer network utilizes up-to-date anti-virus, anti-spyware and data encryption software applications. The Network Administrator is responsible for such software maintenance.
Access to computers and TNCT’s network is secured by individual and unique passwords. No persons other than authorized TNCT employees, the Network Administrator, and/or authorized service persons shall have access to any TNCT computer or server.
3.05 Retention and Destruction of Personal Information
Town n’ Country Title, LLC has defined and communicated to employees the types of data/information that falls into the NPI category. Any NPI data is disposed of accordingly. Paper records by shredding. Shredding bins are located in each office. When disposing of computers and portable storage devices, TNCT uses a trusted third-party company that is nationally certified in IT disposal (Harter’s/Dynamic Lifecycle Innovations).
3.06 Overseeing Service Providers
If independent service providers for TNCT receive NPI, TNCT shares this policy document with the service provider and/or conducts appropriate due diligence of the NPI security measures of the service provider before transmitting any NPI data. Service providers are aware they must notify TNCT regarding NPI security breaches of NPI data that has been transmitted.
3.07 Data Breach Incident Reporting
If security breaches occur, proper notification is provided to consumers and law enforcement in accordance with Town n’ Country Title, LLC’s privacy and information security program and disaster management plan.
3.08 Business Continuity and Disaster Recovery
Town n’ Country Title has a documented disaster management plan to ensure adequate back-up, recovery and business continuation procedures. The plan also includes required procedures for notification and response to security incidents and breaches. The plan is called the Town n’ Country Title Disaster-Recovery-Plan. The disaster management plan is reviewed on a 3-year basis by the President/Owner, HR Manager, and each Branch Manager; it is updated as appropriate.
Town n’ Country Title also maintains insurance coverage for such circumstances.
BEST PRACTICE NO. 4 - SETTLEMENT PROCESS
Adopt standard real estate settlement procedures and policies that help ensure compliance with Federal and State Consumer Financial Laws as applicable to the settlement process.
TOWN N’ COUNTRY TITLE, LLC POLICY – NO. 4
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls relating to document recordation and rate/pricing procedures to put TNCT in compliance with applicable contractual obligations and Federal and State Laws.
4.01 Recording Procedures
HOW RECORDINGS ARE PROCESSED
The Closing Specialist is responsible for submitting the documents for recording to the appropriate Register of Deeds office within 2 business days of settlement. If TNCT is not handling the recording of the documents, the Closing Specialist is responsible for sending the documents to the other title company or entity who will process them; this is to be done within 2 business days of settlement. The Closing Specialist is required to know the requirements for recording documents (ie. the format to make a document recordable).
When available and economically feasible, document recordation will be processed electronically via E-recording. When E-recordings cannot be utilized or are not available the Closing Specialist will send the documents for recording to the appropriate Register of Deeds office. TNCT sends documents using a national overnight carrier UPS. The Closing Specialist tracks all packages and a log of all shipments is maintained on the overnight carrier’s website.
Each TNCT branch maintains a Recording Log to monitor all recordings. The Closing Specialist verifies that the documents sent via E-recording or overnight carrier has been recorded. After the documents have been recorded, detailed information such as the document number and date of recording are included in TNCT’s file. For files in Softpro Select, a digital copy of the recording automatically feeds into the file via connection with Simplifile, an electronic document recording provider TNCT uses.
If the documents are rejected for recording, TNCT promptly tends to those rejected documents.
TNCT maintains contact with the appropriate personnel and parties and/or entities to resolve any recording problems. The date of the rejection and the reason for rejection is entered in to the Recording Log/Softpro Select. Within 24 business hours of notice of rejection of a document, the Closing Specialist will contact the party responsible for making the corrections. After the correction has been made, the Closing Specialist will resubmit the document for recording and enter this new submission date into the Recording Log/Softpro Select.
4.02 Pricing Procedures
RATE MANUALS & PRICING
Title insurance policy premiums and endorsements are calculated in accordance with the title insurance underwriter’s promulgated rate manual. Although Town n’ Country Title’s software contains the title insurance underwriter rate calculators, each employee who calculates rates is given a copy of the underwriter’s rate manual to ensure correct fees are being charged for title insurance policy premiums and endorsements. Providing a rate manual to employees also makes them aware of the contractual and statutory rate and pricing requirements.
All applicable rate discounts, such as Simultaneous Issue, Reissue, and Refinance are calculated in accordance with the requirements in the rate manual.
When rate change bulletins are received, each Branch Manager communicates these rate changes to the appropriate parties. New rates are used effective the date provided to TNCT by the underwriter.
Each file is subject to a post-closing review by the Finals Specialist to conclude if fees were correctly charged. If an overcharge of the premium rate has occurred, the Finals Specialist shall promptly tell the Branch Manager of the error. The Branch Manager will then request a check from the President/Owner for the difference between the correct premium and what was inadvertently charged. This refund for overpayment of the premium shall be returned to the appropriate party within five business days of the discovery of the error.
Newly hired personnel who will be responsible for calculating rates as a part of their job are advised of the procedures to follow for the recording of documents and pricing for policy premiums. They are required to sign a form that they agree to abide by these procedures.
If a person is promoted to a position in which they will be calculating rates, that person is advised of the procedures to follow for the recording of documents and pricing for policy premiums. He or she is required to sign a form that they agree to abide by these procedures.
As changes are made to the recording procedures and/or the pricing of policy premiums, all employees will receive written notification of the changes and are expected to comply with them.
On an annual basis by calendar year, Closing Department employees shall attend a training session to review the company’s recording and pricing procedures. Additionally, other training sessions may be held throughout the year, as needed.
A log of all training sessions will be kept by the HR Manager to maintain compliance with this requirement.
BEST PRACTICE NO. 5 - POLICY PRODUCTION, DELIVERY, REPORTING AND PREMIUM REMITTANCE
Adopt and maintain written procedures related to title policy production, delivery, reporting and premium remittance.
TOWN N’ COUNTRY TITLE, LLC POLICY – NO. 5
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls relating to title policy production, delivery, reporting and premium remittance as necessary to meet its legal and contractual obligations.
5.01 Title Policy Production and Delivery
The Company receives its policy inventory directly from the insurer via the electronic policy application. A Policy Inventory Report is available in the application to track and monitor all of the electronic policy numbers allocated to TNCT. The following items are included in the Policy Inventory report:
- The electronic policies are received by TNCT
- The file number associated with each policy number
- Unused policies
- Voided policies
- Policy numbers assigned, but not yet reported to the insurer
- Policy issued, but not yet reported to the insurer
In addition to the Policy Inventory report, TNCT has a tracking system that identifies files that have closed for which policies have not been issued. Electronic policy stock is limited to authorized users with login and passwords. Authorized users are determined by the underwriters. Policy inventory duties have been clearly defined and are the responsibility of the Branch Manager. We can reconcile our policy inventory records with the Insurer’s records.
Policies are issued to customers (lender and/or purchaser) within 30 days of either the later of when the transaction is disbursed or all of the conditions as shown on the commitment have been met. Electronic logs are maintained within the software system to monitor all orders that have closed and disbursed in which final policies have not been issued. If TNCT does not perform the settlement, the order is tracked and monitored by the Finals Department to ensure the documents are received 30 days after disbursement.
5.02 Policy Reporting
In accordance with contractual obligations on a monthly basis, TNCT reports to the insurer all title insurance policies (including endorsements), premiums and other fees. Reporting is performed via an electronic upload through the insurer’s electronic reporting web-based system. Physical copies of the policies are emailed (or mailed) to the insurer, as required by contractual obligation. A policy register report is maintained by each office that performs policy production.
Newly hired personnel are advised of the procedures to follow for policy production reporting and, premium remittance, if applicable to their job/position. These employees are required to sign a form that they agree to abide by these policies and procedures.
If a person is promoted to a position in which they will be responsible for policy production reporting and, premium remittance, that person is advised of the procedures to follow pursuant to this Pillar. He or she is required to sign a form that they agree to abide by these procedures.
If the procedures and policies regarding policy issuance and reporting change due to the underwriters’ requirements or due to the internal procedures of TNCT, all applicable employees are made aware of these changes and a training class is held to explain the new procedures.
5.03 Premium Remittance
Premium remittance duties are the responsibility of the Closing Specialist. We are able to reconcile the premiums and fees we charged to our customers with the premiums and fees remitted to the insurer. TNCT’s title production software automatically calculates the amount of the remittance premium however a double check of this amount is performed by the Closing Specialist when the underwriter’s remittance premium check is sent. Premium checks that are owed to the underwriter are written from a separate account that is maintained for all the offices. Only the Accounting Administrator along with the President/Owner have access to this account. These checks are sent to the correct underwriter compliance with TNCT’s contractual obligations.
BEST PRACTICE NO. 6 - PROFESSIONAL LIABILITY INSURANCE AND FIDELITY COVERAGE
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls relating to professional liability coverage (errors and omissions insurance, fidelity and surety bond) and so that TNCT has the financial capacity to cover its professional services obligations.
TOWN N’ COUNTRY TITLE, LLC POLICY – NO. 6
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls relating professional liability coverage (errors and omissions insurance, fidelity and surety bond) and so that TNCT has the financial capacity to cover its professional services obligations.
6.01 Professional Liability Insurance and Fidelity Coverage
PROFESSIONAL LIABILITY INSURANCE COVERAGE – ERRORS AND OMISSIONS
Town n’ Country Title, LLC carries professional liability insurance for errors and omissions
in accordance with its contractual obligations to its underwriters, First American Title Insurance Company and Old Republic National Title Insurance Company. The Company furnishes copies of all the insurance policies, endorsements, and proof of payment of the current premium to their title underwriters.
Town n’ Country Title’s professional liability insurance for errors and omissions is in the amount of $1,000,000 per occurrence with a $2,000,000 aggregate limit issued by Wilson Mutual Insurance Company, a company acceptable to our title insurance underwriters. This comprehensive liability policy has a deductible of no more than $5,000 per loss. A copy of the most current policy is available upon request.
The Owner/President is responsible for both tracking the renewal date of the policy and the renewal of all insurance coverages.
On an annual basis, at the time of policy renewal, the Owner/President shall review the current professional liability policy for errors and omissions to determine if additional coverage is needed. Factors to be considered when determining if additional coverage is necessary include but are not limited to: the current number of employees, the number of offices, the services offered, and the current volume and types of business. In determining what coverage is needed, the Owner/President shall also consider TNCT’s growth potential in terms of the number of employees and volume of orders.
FIDELITY BOND COVERAGE
Although fidelity coverage is not required by Wisconsin or Minnesota state law or by contractual obligation with TNCT’s underwriters, Town n’ Country Title, LLC maintains a business owners insurance policy as protection against the dishonest acts of employees. A copy of TNCT’s summary of insurance is available upon request.
CLOSING PROTECTION LETTER
A Closing Protections Letter (CPL) can be issued when requested by the customer. TNCT, through its underwriters, will issue an insurer’s CPL in connection with the settlement funds and issuance of a title insurance policy.
SURETY BOND COVERAGE
Surety bond coverage is not required in the States of Wisconsin and Minnesota.
BEST PRACTICE NO. 7 – CONSUMER COMPLAINTS
Adopt and maintain procedures for resolving consumer complaints to ensure that TNCT is addressing issues of poor service to the consumer and/or issues of non-compliance.
TOWN N’ COUNTRY TITLE, LLC POLICY – NO. 7
Town n’ Country Title, LLC (TNCT) has established and will maintain the following procedures and controls relating to tracking and resolving consumer complaints.
7.01 Recordation and Response
DEFINITION OF A COMPLAINT
Any matter brought to the attention of TNCT which is the result of the insured consumer’s dissatisfaction with the services, charges, or commitments/policies of Town n’ Country Title, LLC.
INTAKE OF A COMPLAINT
All phone calls and emails that refer to a consumer complaint shall be referred to the Branch Manager for each TNCT office. The Branch Manager shall complete the initial intake form and then electronically submit it to the HR Manager who shall be the company’s Compliance Officer.
An initial intake form shall be used to obtain information necessary information to investigate and resolve the matter. This form also connects a consumer complaint to a specific transaction.
An initial response to consumer complaints shall be made within five (5) business days following the receipt of the complaint. If the Branch Manager is making the initial response to the consumer, he or she shall notify the Operations Manager as to this fact.
Where the Branch Manager cannot resolve the complaint to the satisfaction of the complainant, the issue shall be elevated to TNCT’s Operations Manager. Where the Operations Manager cannot resolve the complaint to the satisfaction of the complainant, the issue shall be elevated to the Owner/President. If the Owner/President cannot resolve the complaint to the satisfaction of the complainant, the issue shall be referred to the applicable underwriter, First American Title Insurance Company, Old Republic National Title Insurance Company, or Alliant National Title Insurance Company for advice and/or resolution.
The HR Manager shall be notified when and how a complaint is resolved, if it is resolved by someone other than the Operations Manager. After resolution, the HR Manager shall update the intake form and the complaint database to reflect that the matter has been resolved and how it was handled.
Complaints shall be resolved in a time frame that is practical for the particular issue.
Notice of complaint will be kept for three (3) years following the resolution of the issue after which it will be purged in a secure manner, such as shredding.
ACCESS TO COMPLAINT INFORMATION
The HR Manager shall maintain an electronic folder called Consumer Complaint Intake Forms and will be held on the M:Drive (Corporate Management Drive) for security. Branch Managers shall only have access to the Intake Forms for their particular office upon request. Only the HR Manager and Owner/President shall have access to all binders.
Only the HR Manager, Operations Manager, and Owner/President shall have access to the Consumer Complaint Log.
If a complaint involves a specific person, that individual will be told of the complaint and given the opportunity to review the complaint intake form. The employee shall not have access to view the database or the binder of other initial complaint intake forms.
Once a complaint has been filed and the initial intake form completed, the HR Manager of Town n’ Country Title logs any incident that is designated as a “complaint” into the Town n’ Country Title Consumer Complaint Log. This database is used to track the status of complaints. This Excel spreadsheet log is entitled Consumer Complaints and is located on the M:Drive (Corporate Management Drive) in a file labeled TNCT Consumer Complaints.
A separate log is maintained for each calendar year.
7.03 Analysis and Self-Assessment
REVIEW OF COMPLAINTS
On a quarterly basis, the Owner/President and HR Manager shall review the complaints, specifically looking for trends and the types of complaints filed. Based on the outcome of their review, changes to the complaint intake and resolution procedures may be modified, as needed.
As a result of the quarterly review, changes may be made to TNCT’s closing, examining, and searching policies and procedures to help alleviate future consumer complaints.
Newly hired personnel are advised of the procedures to follow in the event of a consumer complaint. They are required to sign a form that they agree to abide by these procedures and assist in a complaint investigation, as necessary.
As changes are made to the consumer complaint policies and procedures, all employees will receive written notification of the changes and are expected to comply with them.
On an annual basis by calendar year, all TNCT employees shall attend a training session to review the consumer complaint procedures. Additionally, other training sessions may be held throughout the year to cover other customer service issues.
A log of all training sessions will be kept by the HR Manager to maintain compliance with this requirement.