ESCROW ACCOUNT MANAGEMENT COMPLIANCE CHECKLIST (AUDITING, SECURITY)

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--- ESCROW ACCOUNT SETUP & AUTHORIZATION ---
[ ] Escrow Account Number
[ ] Financial Institution Name (Bank of America, Wells Fargo, Chase, Other - Please Specify)
[ ] Description of Escrow Account Purpose (e.g., Property Taxes, Insurance)
[ ] Escrow Account Opening Date
[ ] Authorized Signatories (Signatory 1, Signatory 2, Signatory 3)
[ ] Primary Signatory Authorization Level (Full Authorization, Limited Authorization - Specify Limits)
[ ] Copy of Authorized Signatory Documentation (e.g., Power of Attorney)
[ ] Specific Authorization Limits for Each Signatory (if applicable)

--- CLIENT IDENTIFICATION & VERIFICATION (CIP) ---
[ ] CIP Method Used? (Knowledge-Based Authentication, Identity Proofing, Non-Credible Data Sources)
[ ] Copy of Government-Issued Photo ID (e.g., Driver's License, Passport)
[ ] Detailed Notes on Identity Verification Process
[ ] Social Security Number (SSN) Verification Method (if applicable)
[ ] Address Verification Method Used? (Utility Bill, Bank Statement, Credit Report, Other (Specify in Long Text))
[ ] Details of Address Verification (If Not Standard Document)
[ ] Date of CIP Verification Completion
[ ] Client Type? (Individual, Business Entity)

--- FUNDS HANDLING & DISBURSEMENTS ---
[ ] Maximum Daily Disbursement Limit Per Transaction
[ ] Disbursement Approval Workflow (e.g., Single Signatory, Dual Control) (Single Signatory, Dual Control, Tiered Approval Levels)
[ ] Last Review Date of Disbursement Authority Matrix
[ ] Description of Procedures for Handling Returned Checks/Payments
[ ] Methods Used to Verify Beneficiary Account Information (Select all that apply) (MICR Matching, Independent Verification Services, Direct Confirmation with Beneficiary's Bank, Physical Copy of Voided Check)
[ ] Method for Reconciling Escrow Accounts (Automated Reconciliation Software, Manual Reconciliation, Hybrid Approach)
[ ] Frequency of Escrow Account Reconciliation

--- RECORDKEEPING & DOCUMENTATION ---
[ ] Date of Initial Escrow Agreement
[ ] Description of Escrow Agreement Terms
[ ] Initial Escrow Account Balance
[ ] Copy of Signed Escrow Agreement
[ ] Summary of Relevant Amendments to the Escrow Agreement
[ ] Types of Documents Retained (check all that apply) (Payoff Statements, Title Reports, Insurance Policies, Tax Records, Correspondence, Other (Specify in Long Text))
[ ] Number of Years Records Retained
[ ] Description of Document Storage Method (e.g., Physical, Electronic, Cloud)

--- AUDIT TRAIL & TRANSACTION VERIFICATION ---
[ ] Number of Unique User Logins Reviewed for Audit Trail
[ ] Summary of Audit Trail Review Findings (e.g., anomalies, unauthorized access attempts)
[ ] Date of Last Full Audit Trail Review
[ ] Audit Trail System: is the audit trail comprehensive and tamper-proof? (Yes, No, N/A)
[ ] Transaction Types Included in Audit Trail (Deposit, Withdrawal, Transfer, Fee Assessment, Interest Payment, Reconcilation)
[ ] Sample Audit Trail Log File (for review)
[ ] Verification of Funds Disbursement: Are Funds Disbursement processes and authorization clearly documented and verifiable through the audit trail? (Yes, No, N/A)

--- SECURITY CONTROLS - ACCESS & AUTHENTICATION ---
[ ] Multi-Factor Authentication (MFA) Enabled? (Yes, No, Partial - Some Users)
[ ] Password Complexity Requirements Enforced? (Yes, No, Partial - Some Systems)
[ ] Minimum Password Age (in days)
[ ] Access Review Frequency (Quarterly, Semi-Annually, Annually, Ad-hoc)
[ ] Summary of User Access Review Process
[ ] Privileged Account Management System in place? (Yes, No, In Progress)
[ ] Last Password Policy Review Date
[ ] Authentication methods supported for remote access? (VPN, Remote Desktop Protocol (RDP), Web-based Portal, Other (specify in Long Text))

--- SECURITY CONTROLS - DATA ENCRYPTION & PROTECTION ---
[ ] Encryption Method for Data at Rest: (AES-256, Triple DES, Other (Specify in LONG_TEXT))
[ ] Encryption Method for Data in Transit: (TLS 1.3, TLS 1.2, SSL 3.0 (Not Recommended))
[ ] Detailed Description of Data Encryption Key Management Procedures:
[ ] Data Loss Prevention (DLP) Measures in Place? (Yes, No, In Progress)
[ ] Frequency of Data Encryption Key Rotation (in days):
[ ] Firewall Protection in Place? (Yes, No, In Progress)
[ ] Description of Vulnerability Scanning and Penetration Testing Procedures:
[ ] Latest Penetration Testing Report (PDF)

--- BUSINESS CONTINUITY & DISASTER RECOVERY ---
[ ] Last Disaster Recovery Drill Frequency (in months)
[ ] Date of Last Business Continuity Plan Review
[ ] Brief Description of Business Continuity Plan Highlights
[ ] Critical Systems Included in Disaster Recovery Plan (Select all that apply) (Escrow Software, Email Server, Accounting System, Communication Systems (Phone, Internet), Document Storage (Cloud or On-Site))
[ ] Backup Location Type (Offsite Cloud Storage, Secondary Physical Location, Hybrid (Cloud & Physical), Not Applicable)
[ ] Copy of Current Business Continuity Plan (BCP)
[ ] Describe Communication Plan for Alerting Key Personnel in Case of Disaster
[ ] Is a Succession Plan in place for Key Personnel? (Yes, No, Pending)

--- REGULATORY COMPLIANCE (FEDERAL & STATE) ---
[ ] Are you registered with the state's Escrow Regulatory Agency? (Yes, No, N/A - Not Required)
[ ] Date of last state escrow regulatory agency examination:
[ ] Exam Score (if applicable):
[ ] Summary of any findings from last examination (if applicable):
[ ] Are you complying with the Secure Affordable Financial Transactions Act (SAFE Act)? (Yes, No, N/A)
[ ] Do you adhere to the Real Estate Settlement Procedures Act (RESPA)? (Yes, No, N/A)
[ ] Which state-specific escrow regulations apply to your operations? (California Escrow Law, Florida Escrow Regulations, Texas Escrow Laws, New York Escrow Rules, Other (Specify in Long Text))
[ ] Specify Other State-Specific Regulations (if 'Other' was selected above):

--- TRAINING & COMPETENCY ---
[ ] Which core escrow processes has the employee completed training on? (Funds Receipt & Processing, Disbursement Procedures, Client Identification (CIP), Document Management, Closing Procedure Adherence, Security Protocols)
[ ] Date of last escrow compliance training.
[ ] Number of years of experience in escrow operations.
[ ] Describe the content of the escrow compliance training.
[ ] What level of proficiency does the employee demonstrate in performing key escrow tasks? (Expert, Proficient, Developing, Needs Improvement)
[ ] Upload copy of training certificate/proof of completion.
[ ] Date of next scheduled refresher training.

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