Wire fraud starts in the inbox. So does the fix.
Nearly every diverted closing begins with a compromised or spoofed mailbox. Alden locks down the inboxes where instructions arrive, watches them around the clock, and writes ALTA Pillar 3 and the FTC Safeguards Rule into one program your underwriter, your lenders and your carrier can read.
Three obligations. One program.
A title or escrow agency answers to its underwriters, to the FTC, and to the lenders and buyers whose money moves through its trust account. The same controls and the same evidence satisfy all three. Alden builds the program once and keeps it running.
ALTA Best Practices, Pillar 3
Pillar 3 asks every agent to adopt and maintain a written privacy and information security program. Your underwriter asks for proof of it, usually once a year, and some ask for third-party certification.
- ✓Written program covering access, network security, disposal, training and incident response
- ✓A named person responsible for the program
- ✓Oversight of closing software, e-signature, notary and cloud vendors
- ✓Evidence package for the self-assessment or certification
FTC Safeguards Rule
Settlement services are financial institutions under Gramm-Leach-Bliley, so the amended Safeguards Rule (16 CFR Part 314) applies in full. It names specific controls, and requires notice to the FTC within 30 days when a breach affects 500 or more consumers.
- ✓Qualified Individual, written risk assessment and annual report to ownership
- ✓Multi-factor authentication for everyone who touches customer information
- ✓Encryption, access controls, logging and monitoring
- ✓Written incident response plan, staff training and service-provider oversight
Wire fraud at the closing table
Diverted closings almost always start in email: a forwarding rule nobody noticed, a look-alike domain, a last-minute change to payoff instructions. The controls that stop it are technical and procedural, and both have to be evidenced.
- ✓Phishing-resistant sign-in, legacy authentication blocked, external forwarding disabled
- ✓SPF, DKIM and DMARC enforced on every domain you send from
- ✓Call-back verification to a known number before any instruction changes
- ✓Written response plan for the first hours after a suspected diversion
Twenty minutes tells you where your program stands and what the assessment would cover.
Everything you get, and who asks for it.
Every line is included in the monthly agreement unless it says otherwise. A dot means that source asks for the item.
$995 to start with the assessment, onboarding at $200 per user, then a monthly rate per user, set in your agreement before you sign. The fit call tells you whether it fits your agency.
The first hours after a suspected diversion are scripted in advance.
A written response plan, rehearsed once a year in a tabletop exercise, tells your closers exactly who to call, what to freeze and what to document — and a 24/7 detection team is already looking at the mailbox before you finish the first call.
Contain
Managed detection isolates the account; forwarding rules and sessions are revoked under a pre-approved action list.
Recall and notify
Bank recall request from the plan's checklist; underwriter, lender and carrier notified in the order the plan specifies.
Evidence and reporting
Timeline, exports and decisions filed; FTC notice prepared if the threshold is met; lessons folded back into the program.
Start with a conversation, not a contract.
Twenty minutes to confirm fit. If it fits, you start with a $995 assessment that counts toward onboarding: three weeks, a ranked findings report, yours to keep either way.
How we describe our work
Alden's assessments are point-in-time observations against named standards: ALTA Best Practices, the FTC Safeguards Rule and your insurer's application as written. We build and operate controls and produce the evidence behind them. We do not audit or certify your firm, and we do not provide legal advice. Your firm reviews and signs its own attestations. Regulators and insurance carriers make their own determinations; our work supports insurability and exam readiness, it does not guarantee either. Our controls reduce the likelihood and impact of the attacks described; no control prevents all of them.