🐐Frozen FIRPTA, Fiery RESPA, and How Title Agents Can Cash In
This Week in the Title Underground (9-Nov-2025): FIRPTA’s frozen, RESPA’s heating up, and Fannie just torched the credit score floor. Title chaos? We call it Tuesday. Here’s what to do next.
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🐐 This Week in the Title Underground
FIRPTA’s frozen, RESPA’s heating up, and Fannie Mae just pulled the floor out from under credit scores. In other words—it’s another perfectly normal week in title land.
Here’s what we’re digging into:
⚖️ Regulators are restless. FinCEN wants to know what compliance really costs, the CFPB is staffing up for more RESPA enforcement, and how to make sure your friendly marketing “favors” don’t become violations.
🏠 Credit scoring just blew wide open. VantageScore is in, FICO minimums are out, and a wave of first-time buyers and bankruptcy survivors could be back in play. Get ready for more deals—and more chaos.
📄 Weird title problems, wild solutions. From churches selling land for housing to HOAs ghosting their own payoffs, our curative files this week prove divine intervention is no substitute for due diligence.
💼 Thinking about selling your shop? Adam Coffey breaks down how private equity really looks at title companies (hint: they pay more for order than for adrenaline). We added a quick-hit checklist to make your business acquisition-ready.
📜Educational Resources
🐐 Get The State-by-State Guide to Title Agency Cancelation & Commitment Fees
📄Why ALTA®/NSPS Surveys Matter in Virginia Residential Real Estate Transactions
📄What to Know When Handling Transactions Involving Church-owned Property - When it comes to church-owned property, divine intervention won’t cure bad vesting. ⛪ Before you praise the zoning gods, check the bylaws—because nothing stalls a deal faster than a missing trustee or a deed written in biblical times.
📄The Claims Corner: Will You Please Let Me Pay You? - Sometimes the hardest part of lien clearance isn’t finding the debt—it’s convincing someone to take the damn check. 💸 Virginia agents, remember Va. Code § 55.1-344 is your get-out-of-voicemail-jail card when a creditor ghosts your payoff.
📄IPEN vs. Remote Online Notarization: Key Differences & Benefits
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🕵️♂️Underworld Intel
UPS plane carrying up to 20,000 packages crashed on Tuesday outside Louisville Kentucky. If you ship via UPS, track your packages. Make sure your payoffs and documents have arrived safely. Aside from damaged packages, package sorting was halted at the Worldport location, cause additional delays.
UPS and FedEx ground all MD-11 planes after deadly Louisville crash - this could cause additional shipping delays. Keep an eye out for notices from your shipping vendors and consider signing up for Closinglock’s SecurePay for alternative ways to fund your transactions.
🌍 Foreign Tax CPA: How the Government Shutdown Is Affecting FIRPTA Right Now - The IRS is on coffee break, but your FIRPTA clock isn’t. ⏰ Every remitted document is stuck in purgatory, but the deadlines? Still ticking. Penalties? Still real. Expert help? Necessary.
📄🔒Closinglock SecurePay Recognized at Money20/20 for Redefining How Money Moves in Real Estate
📄The Quiet Revolution in Multifamily: Why Yesterday’s Buildings Are Today’s Goldmine - Investors are flocking to “vintage” apartments built before most of us were born and every one of those buildings carries decades of liens, easements, and ownership quirks. For title pros, that’s not a headache, it’s a business line: curative work, entity-layer closings, and repeat refis as these assets trade hands. Yesterday’s buildings are tomorrow’s files, if you’re ready to clear their ghosts. More on this coming soon.
📰America’s first-time homebuyers are disappearing. That’s bad news for real estate. But maybe FHFA’s new change to credit scores will bring them back (I dig in below with details)
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⚖️Regulatory & Policy Updates
📢FinCEN Seeks Comments on Proposed Survey of the Costs of AML/CFT Compliance for Insurance Companies (Comment period closes Dec 1, 2025)
📰Senate hearing highlights tensions over HUD layoffs and housing access
📰Trump Administration Fires Mortgage Regulator Watchdog and Fannie Mae Ethics Staff
📰New Fannie, Freddie housing goals may hurt working families
📰Trump Administration Removes FHFA Inspector General Joe Allen
🎥The RESPA enforcement landscape is shifting. Are you prepared? (Webinar)
💥 What to Do Before the Regulators Come Knocking
Audit your relationships. Pull every MSA, JV, and co-marketing deal—if it can’t survive a sunlight test, it won’t survive an examiner.
Lock down your Compliance Management System. Document your compliance procedures like someone’s about to ask for them (because they are).
Watch the compensation creep. Don’t let “friendly favors” and “marketing ploys” turn into violations.
Train your people. Staff should know what “RESPA Section 8” means before a regulator asks, not after.
🧩 Key Changes in Credit Scoring for Mortgage Markets and What this Means for Title Business Opportunities
New Score Models Approved: In 2022 Federal Housing Finance Agency (FHFA) validated both VantageScore 4.0 and FICO 10T as acceptable for loans delivered to Fannie Mae and Freddie Mac, but said it would take years to implement.
What’s the Difference Between FICO & VantageScore? The newer models (especially VantageScore 4.0) incorporate “alternative data” such as rent, utility and telecom payment history, and don’t require as long a credit-file history as older models. This is not a “social credit score“ - that’s a different thing entirely and not currently used for mortgage approvals.
Fannie Mae Removes Minimum Credit Score Requirements - Fannie Mae’s latest update eliminates minimum credit score requirements effective Nov. 16, 2025. This change aims to broaden borrower access but raises industry concerns about risk assessment and transparency. This change to the official Fannie Mae Selling Guide means minimum credit score requirements of 620 for single-borrower loan files and minimum average credit score requirements of 620 for multi-borrower files will no longer apply for Fannie-eligible loans.
Implementation Challenges & Transition Phase: Despite the approvals, practical roll-out is uneven—systems, underwriting, pricing adjustments (LLPAs), and investor acceptance are all still in flux.
Why Fannie and Freddie still won’t accept more inclusive credit score - FHFA Director Bill Pulte ordered the mortgage giants to start using VantageScore 4.0 in July. But adoption is a ‘complex, technical and arcane’ process that could drag into next year
What this means for your title business: new business opportunities
First Time Homebuyers: Getting mortgage approval for first time home buyers, especially those with a rental history, is going to get easier. Partner with your real estate agents to help get the word out to Millennials who have given up hope of ever owning a home (ages 28-45) and older Gen Zers who never thought it was possible in the first place.
Bankruptcy Survivors from the ‘08 Crash: The removal of credit score minimums may open the doors of homes to those who’s financial lives were devastated by the housing crash in ‘08.
College Graduates: They may not have much credit history yet. Now, that might be ok.
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💸Business Growth & Operations
⚙️ 3 Fast Ways to Make Your Title Company Acquisition-Ready
🎥Unlock the keys to skyrocketing your title business’s value
1. Get your financials out of the junk drawer.
Private equity buyers don’t pay for chaos—they pay for clarity. Clean up your books, separate business from personal expenses, and make sure revenue and cost centers are clearly defined.
2. Systematize what’s in your head.
If the business can’t run without you, it’s not an asset—it’s a hostage. Document workflows, delegate authority, and make your processes reproducible.
3. Trim emotional baggage.
Kill vanity projects, legacy hires, and “we’ve always done it this way” habits. The leaner and more disciplined your operation, the higher your valuation (and the shorter your due-diligence nightmare).
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📻Your Title Playlist
Title Trouble from Rebecca Gomes, an Underwriter at Fidelity
🐐 This Wednesday’s Deep Dive:
Get ready for the 2025 ALTA One Wicked Awards — our semi-official, totally un-sanctioned round-up of the best & boldest. It’s a not-so-serious look at the serious business of title. 🏆
I’ll share my favorite vendors, a few honorable mentions for “creative chaos,” and plus clips from my chat with Nancy Gusman of Brickhouse Consulting on how to squeeze every drop of value out of big industry events.
Expect candid tips, my personal opinions (as if you wanted that!), and maybe a photo or two that proves title people do leave their offices occasionally. Half the magic of ALTA One happens between sessions, in line for coffee, or during a spontaneous lobby bar strategy meeting at 1am. Come for the awards, stay for the real talk and the trip pics, because the swag bags are temporary, but good vendor intel lasts all year.. 👇
👉 Upgrade now to get all the inside dirt!
Another week, another mountain of news, rules, and real estate chaos sorted into something you can actually use. From frozen FIRPTA funds to fiery RESPA warnings to the credit-score revolution that might just bring first-time buyers back from extinction — you’re officially caught up, and probably a little smarter than your competition.
This edition has been brought to you by our amazing paid members, and our sponsors: Brickhouse Consulting, Closinglock, Dotted Line Signings, Foreign Tax CPA, & Razi Exchange.
If something here made you laugh, think, or forward this email to your team, that’s the good stuff. Keep showing up, keep asking questions, and keep the industry honest.
Until next time — stay wicked, stay sharp, and remember: in title, calm is just the pause before another policy change.
Wicked Title Forum maintains its independence through the support of readers like you. This post has been free for you to read thanks to their generous support and belief in our mission. Each Title Underground takes about 4-6 hours to compile and a review of almost 500 news stories, blogs, podcasts and videos from hundreds of sources. If you enjoyed this news recap and want to ensure we continue to create valuable content for the title insurance industry, please consider supporting us…
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Stay Wicked,
Cheryl
Contact Me (or hit reply)
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