The title industry was surprised by the proposed regulation 208 last week.  Left unchecked, this unworkable regulation would create unnecessary and unanticipated consequence while failing to bring about its purported objective of driving costs out of the system and resulting in lower premiums for consumers.

The Executive Committee is meeting on May 12th to discuss our response and approve a strategy for the 45-day comment period that ends June 22nd.

When faced with a threat to one's livelihood, an emotional reaction is natural and understandable. However, a successful strategy must be based on reason and calculation.  The process starts with being informed and understanding the governmental process.

If you have not read the proposed regulation - you can see it here:

http://www.dfs.ny.gov/insurance/rproindx.htm

Here is a flow chart to help understand SAPA (State Administrative Procedures Act), which determines the process:  http://www.dos.ny.gov/info/rulediagram.html

These are the first steps. We have a long way to go.