Escrow Account Management Compliance Checklist (Auditing, security)
Ensure your real estate escrow accounts are secure & compliant! Download our comprehensive checklist covering auditing, security protocols, and regulatory requirements. Protect your business & clients - get peace of mind today! #realestate #escrow #compliance #security #auditing
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Escrow Account Setup & Authorization
Verifies proper account creation, authorized signatories, and delegation of authority.
Escrow Account Number
Financial Institution Name
Description of Escrow Account Purpose (e.g., Property Taxes, Insurance)
Escrow Account Opening Date
Authorized Signatories
Primary Signatory Authorization Level
Copy of Authorized Signatory Documentation (e.g., Power of Attorney)
Specific Authorization Limits for Each Signatory (if applicable)
Client Identification & Verification (CIP)
Ensures adherence to Customer Identification Program (CIP) requirements for all parties involved.
CIP Method Used?
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?
Details of Address Verification (If Not Standard Document)
Date of CIP Verification Completion
Client Type?
Funds Handling & Disbursements
Covers processes related to receipt, safekeeping, and disbursement of escrow funds.
Maximum Daily Disbursement Limit Per Transaction
Disbursement Approval Workflow (e.g., Single Signatory, Dual Control)
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)
Method for Reconciling Escrow Accounts
Frequency of Escrow Account Reconciliation
Recordkeeping & Documentation
Focuses on maintaining accurate, complete, and accessible records of all transactions.
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)
Number of Years Records Retained
Description of Document Storage Method (e.g., Physical, Electronic, Cloud)
Audit Trail & Transaction Verification
Addresses the ability to track and verify all activity within the escrow accounts.
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?
Transaction Types Included in Audit Trail
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?
Security Controls - Access & Authentication
Covers security measures related to user access, passwords, and multi-factor authentication.
Multi-Factor Authentication (MFA) Enabled?
Password Complexity Requirements Enforced?
Minimum Password Age (in days)
Access Review Frequency
Summary of User Access Review Process
Privileged Account Management System in place?
Last Password Policy Review Date
Authentication methods supported for remote access?
Security Controls - Data Encryption & Protection
Focuses on protecting sensitive data at rest and in transit through encryption and other security protocols.
Encryption Method for Data at Rest:
Encryption Method for Data in Transit:
Detailed Description of Data Encryption Key Management Procedures:
Data Loss Prevention (DLP) Measures in Place?
Frequency of Data Encryption Key Rotation (in days):
Firewall Protection in Place?
Description of Vulnerability Scanning and Penetration Testing Procedures:
Latest Penetration Testing Report (PDF)
Business Continuity & Disaster Recovery
Ensures plans are in place to maintain escrow services during disruptions.
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)
Backup Location Type
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?
Regulatory Compliance (Federal & State)
Covers adherence to relevant laws and regulations related to escrow accounts, including but not limited to RESPA, SAFE Act, and state-specific requirements.
Are you registered with the state's Escrow Regulatory Agency?
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)?
Do you adhere to the Real Estate Settlement Procedures Act (RESPA)?
Which state-specific escrow regulations apply to your operations?
Specify Other State-Specific Regulations (if 'Other' was selected above):
Training & Competency
Verifies that escrow personnel are adequately trained and competent in their roles.
Which core escrow processes has the employee completed training on?
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?
Upload copy of training certificate/proof of completion.
Date of next scheduled refresher training.
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