Mortgage Banking & Consumer Credit Alert
September 2007
Author:
Shannon Skinner
+1.206.370.7657
shannon.skinner@klgates.com
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The New ALTA Title Insurance Policies:
Making the Leap from 1970 to the
21st Century
The American Land Title Association adopted new forms of owner’s and loan title insurance
policies and endorsements as of June 2006. These forms were the result of a multi-year
process to update, improve and address issues with the 1992 policies. The 2006 policies
include more express insuring clauses, integrate coverage found in endorsements and address
many concerns of customer groups. The wording has been improved with more definitions
and affirmative statements (rather than exceptions within exclusions). Nevertheless, for
many sophisticated consumers of title insurance, the 1970 forms of policy were preferred
to the 1992 policies, and the 1992 policies were not widely accepted if the 1970 forms were
available. For these insureds, the more relevant comparison is with the 1970 policies.
The ALTA estimates that the 2006 policies will be adopted and available for use in all
states by spring 2007. Also, although the older forms may not necessarily be withdrawn as
approved forms in a state, they will become generally less available as the title companies
try to move their customers to the new forms. In addition, the ALTA is likely to withdraw
the older forms as official ALTA forms. So, the question is whether the time has come to
change title insurance policy requirements and move to the 2006 forms. Overall, the 2006
policies have much to recommend them and little, if any, that is less favorable to the insured
(and most of this can be addressed through endorsements).
One principal feature of the new policies is new express insuring clauses. At least two
appellate cases have held that for there to be coverage in a title policy, it must be expressly
stated in the insuring clauses. E.g., Somerset Savings Bank v. Chicago Title Insurance Co.,
649 N.E. 2nd 1123 (Mass. 1995); Lick Mill Creek Apartments v. Chicago Title Insurance Co.,
283 Cal. Rptr. 231 (Cal. App. Dist. 1991). An exception from an exclusion from coverage
may not, therefore, provide insurance. Certainly the title companies increasingly take the
view that an express insuring clause is required. For example, the 1970 policy does not
include insuring clauses affirmatively covering police power actions or environmental
liens; rather, there is an exception to these exclusions if notice has been recorded. The
2006 policies expressly cover these to the extent that notice is recorded in the appropriate
records. New coverages are automatically included, such as against preferences arising
from untimely recording and gap recordings. The list of insured parties is expanded and
the 90 day requirement for giving proof of loss is deleted. A check the box list of ALTA
endorsements allows many of these to be incorporated into the loan policy by reference. The
apportionment provision of the owner’s policy is deleted (and the 1992 co-insurance clause
was not included). A more detailed comparison of the policy forms are attached as Exhibits
L (Loan) and O (Owner).
In addition to the new policy forms, the ALTA promulgated many new endorsements. Some
of these, like the access/abuts street, are improved in their coverage. The endorsement forms
that have been modified to match the 2006 policies have the “-06” designation after the
number.
Mortgage Banking & Consumer Credit Alert
Given the improvements in the express insuring
clauses and endorsements, as well as the convenience
factor from greater availability and improved
readability, the 2006 policies on balance are superior
to the 1970 policies. This assumes that the insured
obtains endorsements deleting the creditor’s rights
exclusion and the arbitration provision (for policies
under $2 million), which was the practice when using
the 1992 policies. The proof of loss/examination under
oath provisions are more onerous on insureds from
the 1970 forms but these do not seem unreasonable.
Insureds cannot rely on a court finding that deleting
an exception or an exception to an exclusion provides
affirmative coverage. Thus, commercial real estate
owners and lenders should become familiar with the
2006 policy forms and begin using them in their
transactions.
Exhibit L—Loan Policy Comparison
Exhibit O—Owner’s Policy Comparison
EXHIBIT L
LOAN POLICY
COMPARISON OF 2006 AND 1970 ALTA POLICIES
(Note: when using the description of a provision as “same” below, this is meant to describe provisions that are
essentially the same in effect or similar even though wording may be different.)
2006
1970
Covered Risks
Covered Risks
Title being vested other than as stated.
Same.
Defect, lien or encumbrance on title, including by reason
of forgery, fraud, undue influence, duress, incompetency,
incapacity or impersonation; failure of entity to authorize,
improper execution formalities; improper document
creation by electronic means allowed by law; execution
under invalid power of attorney; improper recording/
indexing; defective judicial/administrative proceeding.
Same, except list of risks not included.
Lien of real estate taxes or assessments due but unpaid.
Encroachments, encumbrance, violation, variation or
adverse circumstance that would be disclosed by accurate
survey. Encroachment includes encroachment of
improvements on insured land onto adjoining property.
Not expressly included; subsumed in lack of
priority.
Not expressly included; was thought to be achieved
by deleting the survey exception. Encroachments
off of land possibly not covered because outside
of insured land. See Transamerica Title Ins. Co.
v. Northwest Building Corp., 733 P.2d 431 (Wn.
App. 1989).
Unmarketable title (including right to refuse to buy, lease
or lend).
Unmarketable does not include refusal to lease
or lend.
No right of access to insured land.
Same.
September 2007 | 2
Mortgage Banking & Consumer Credit Alert
Violation or enforcement of laws (including those relating
to building and zoning) restricting, regulating, prohibiting
or relating to occupancy, use and enjoyment of the land,
dimensions, subdivision, environmental protection or
under exercise of police powers IF notice is recorded
in public records (which includes district court for
environmental liens).
Coverage was thought to be included through
exception to exclusion from coverage.
Exercise of rights of eminent domain if notice recorded
in public records.
Coverage was thought to be included through
exception to exclusion from coverage.
A taking that has occurred and is binding on rights of
BFP.
Not expressly included; subsumed in title being
vested other than as stated.
Invalidity of lien of insured mortgage, including by reason
of forgery, fraud, undue influence, duress, incompetency,
incapacity or impersonation; failure of entity to authorize,
improper execution formalities; improper document
creation by electronic means allowed by law; execution
under invalid power of attorney; improper recording/
indexing; defective judicial/administrative proceeding.
Same, except that list of risks not included.
Exception for usury and consumer protection
moved to Exclusions.
Lack of priority of insured mortgage over any other lien
or encumbrance.
Same.
Lack of priority of insured mortgage (i) as security
for each advance over construction liens arising from
improvements or work contracted for or commenced
before date of policy; (ii) contracted for, commenced
or continued after date of policy and funded by loan
secured by insured mortgage that insured has advanced
or is obligated to advance as of date of policy; or (iii)
over lien of assessments for street improvements under
construction or completed as of date of policy.
Same, except not include (iii) (was covered under
ALTA Endorsement Form 1).
Invalidity of assignment of insured mortgage if shown on
Schedule A or failure of assignment to vest title to insured
mortgage in named insured free of liens.
Same.
Invalidity of insured mortgage by reason of (i) avoidance
of transfer of land constituting fraudulent conveyance or
preference under bankruptcy or other creditor’s rights
laws occurring BEFORE the transaction creating the
lien of the insured mortgage; or (ii) insured mortgage
constituting a preference because of untimely or improper
recording.
Not addressed in 1970 policy and was subsumed
in insuring clause 1 (title being vested other than
as shown). Was exception to exclusion in 1992
policy. Clause (ii) is express new coverage in
2006 policy.
September 2007 | 3
Mortgage Banking & Consumer Credit Alert
Any other defect or encumbrance on title or other matters
included in covered risks that is created, attaches or is
recorded in public records after date of policy but before
recording of insured mortgage.
New express gap coverage.
Express statement that title co. will pay costs and
attorney’s fees incurred in defense of insured matter to
extent provided in conditions.
Exclusions from Coverage
Exclusions from Coverage
Laws (including those relating to building and zoning)
restricting, regulating, prohibiting or relating to
occupancy, use and enjoyment of the land, dimensions,
subdivision, environmental protection, or violations/
enforcement thereof, or police powers (UNLESS covered
under insuring clause, which covers if notice is recorded
before date of policy).
Same, except coverage if notice is recorded was
exception to exclusion, not affirmative coverage.
Rights of eminent domain (UNLESS covered by insuring
clause, which covers if notice is recorded before date of
policy ).
Same, except coverage if notice is recorded was
exception to exclusion, not affirmative coverage.
Defects, liens, encumbrances, adverse claims and other
matters (i) created, suffered, assume or agreed to by
the insured claimant; (ii) not known to the title co., not
recorded but known to the insured and not disclosed in
writing; (iii) resulting in no loss or damage; (iv) attaching
subsequent to date of policy (although this does not limit
certain coverages that have post-policy elements); or (v)
resulting in loss that would not have been sustained if
insured had paid value for the insured mortgage.
Same, except (v) not included.
Unenforceability of insured mortgage due to insured’s
failure to comply with doing business laws.
Same.
Unenforceability of insured mortgage due to usury,
consumer credit protection or truth in lending laws.
Same (was exception to coverage).
September 2007 | 4
Mortgage Banking & Consumer Credit Alert
Claim under bankruptcy or other creditor’s rights laws
that the insured mortgage is a fraudulent conveyance
or preference UNLESS covered under insuring clause
(which covers such matters occurring before the insured
mortgage transaction).
1970 policy does not have creditor’s rights
exclusion; this was one of the main objections
to the 1992 policy (although insurers believe that
these matters were not covered under 1970 policy
in any event). With 2006 policy, need to request
endorsement to delete creditor’s rights exclusion.
This is frequently available for routine mortgage
loan transactions. Can be an issue in leveraged
buy-outs and debt restructuring transactions.
Lien for taxes and assessments imposed between
date of policy and recording of insured mortgage.
Not in 1970 policy; added as exception to new gap
coverage in 2006 policy.
Schedule A
Schedule A
Allows check the box to incorporate by reference certain
list of ALTA endorsements (including condo, variable
rate, environmental protection, leasehold, comprehensive,
future advances, location).
No equivalent.
Schedule B
Schedule B
Same.
Same.
Conditions
Conditions
New definitions included for Amount of Insurance, Date
of Policy, Entity, Indebtedness, Insured Mortgage, Title.
Note that “Indebtedness” includes post-policy advances
(e.g., principal, interest, prepayment and exit fees, taxes
and insurance, protective advances), payable as a matter
of damages; this is major benefit for insured.
Expanded definition of Insured, including successor
owner of debt, whether for own account or as trustee;
holder of transferable electronic record; successors of
entity conversions, dissolutions, mergers, reorganizations;
grantee under deed given without consideration to affiliates
and subsidiaries; governmental agencies/instrumentalities
that insure or guaranty the debt. (Note: all defenses are
preserved against other insureds except BFPs for value
and governmental agencies.)
Includes successor owner of debt and governmental
insurers/guarantors
Continuation of Insurance.
Similar.
September 2007 | 5
Mortgage Banking & Consumer Credit Alert
Notice of claim: insured to give prompt notice of litigation,
knowledge of claim or rejection of title as unmarketable.
Coverage is reduced to extent that failure to give prompt
notice prejudices title co.
Equivalent.
Proof of loss; duty to cooperate: Specifies details for proof
of loss; includes duty to make books and records available;
requires insured claimant to submit to examination under
oath. Ninety day period deleted but cooperation is more
onerous on insured than 1970 policy.
Includes requirement to give proof of loss within
90 days after loss is determined. Details on proof
and cooperation not included.
Defense/prosecution of actions.
Equivalent.
Option or pay or settle.
Equivalent.
Extent of liability: includes new provision that if title
co. defends/prosecutes and is unsuccessful, amount of
insurance is increased by 10% or insured has right to
have loss determined either as of date or claim or date
settled and paid.
Limitation on liability, reduction in insurance, termination
of liability. Includes new limit for governmental insurers/
guarantors to amount paid to settle insurance/guaranty
claim.
Equivalent, except does not include bump up
in damages if title co. does not settle and
unsuccessfully pursues litigation.
Payment of loss within 30 days after definitely fixed.
Same.
Title co. rights of recovery after settlement and payment:
title co. has subrogation rights but cannot exercise until
insured has recovered its losses.
Similar. Includes express permission to modify
debt, release collateral or obligors until notice of
claim.
Arbitration: requires arbitration under ALTA rules for
policies of $2 million or less. (AAA dropped its rules for
title insurance disputes.)
Arbitration not included in 1970 policy and was
objectionable feature for many lenders under
1992 policies (although only for policies of $1
million or less, which eliminated most commercial
policies). Endorsement can be requested to delete
arbitration requirement.
Equivalent.
Policy is entire contract: provides for incorporation of
endorsements (which don’t modify policy, extend date or
increase amount unless expressed) so this language won’t
appear in endorsements.
Choice of law and forum is state where land is located.
Not included.
September 2007 | 6
Mortgage Banking & Consumer Credit Alert
Reminders When Using 2006 Loan Policy:
„
You need to request deletion of creditor’s rights exclusion and affirmatively insure against creditor’s rights risk
through ALTA Endorsement 21-06.
„
You need to request deletion of arbitration condition if policy is $2 million or less.
„
Future advance endorsement is required for future advance coverage. Future advances of principal are
arguably not insured because the priority risk is limited to date of policy and post-policy events are excluded.
The reason is because the definition of “Indebtedness” includes future advances but this term is not used in the
covered risks section but rather in the payment of losses and settlement sections. Under the line of cases that
an express insuring clause is required, a future advance endorsement should be requested (and is one of the
boxes that can be checked to have included by reference). Note: advances to protect security are not future
advances and an endorsement is not required for these.
EXHIBIT O
OWNER’S POLICY
COMPARISON OF 2006 AND 1970 ALTA POLICIES
(Note: when using the description of a provision as “same” below, this is meant to describe provisions that are
essentially the same in effect or similar even though wording may be different.)
2006
1970
Covered Risks
Covered Risks
Title being vested other than as stated.
Same.
Defect, lien or encumbrance on title, including by reason
of forgery, fraud, undue influence, duress, incompetency,
incapacity or impersonation; failure of entity to authorize,
improper execution formalities; improper document
creation by electronic means allowed by law; execution
under invalid power of attorney; improper recording/
indexing; defective judicial/administrative proceeding.
Same, except list of risks not included.
Lien of real estate taxes or assessments due but unpaid.
Encroachments, encumbrance, violation, variation or
adverse circumstance that would be disclosed by accurate
survey. Encroachment includes encroachment of
improvements on insured land onto adjoining property.
Not expressly included; subsumed in lack of
priority.
Not expressly included; was thought to be achieved
by deleting the survey exception. Encroachments
off of land possibly not covered because outside
of insured land. See Transamerica Title Ins. Co.
v. Northwest Building Corp., 733 P.2d 431 (Wn.
App. 1989).
Unmarketable title (including right to refuse to buy, lease
or lend).
Unmarketable does not include refusal to lease
or lend.
September 2007 | 7
Mortgage Banking & Consumer Credit Alert
No right of access to insured land.
Same.
Violation or enforcement of laws (including those relating
to building and zoning) restricting, regulating, prohibiting
or relating to occupancy, use and enjoyment of the land,
dimensions, subdivision, environmental protection or
under exercise of police powers IF notice is recorded
in public records (which includes district court for
environmental liens).
Coverage was thought to be included through
exception to exclusion from coverage.
Exercise of rights of eminent domain if notice recorded
in public records.
Coverage was thought to be included through
exception to exclusion from coverage.
A taking that has occurred and is binding on rights of
BFP.
Not expressly included; subsumed in title being
vested other than as stated.
Title being vested other than as stated by reason of (i)
avoidance of transfer of land constituting fraudulent
conveyance or preference under bankruptcy or other
creditor’s rights laws occurring BEFORE the transaction
creating the lien of the insured mortgage; or (ii) insured
mortgage constituting a preference because of untimely
or improper recording.
Not addressed in 1970 policy and was subsumed
in insuring clause 1 (title being vested other than
as shown). Was exception to exclusion in 1992
policy. Clause (ii) is express new coverage in
2006 policy.
Any other defect or encumbrance on title or other matters
included in covered risks that is created, attaches or is
recorded in public records after date of policy but before
recording of deed.
New express gap coverage.
Express statement that title co. will pay costs and
attorney’s fees incurred in defense of insured matter to
extent provided in conditions.
Exclusions from Coverage
Exclusions from Coverage
Laws (including those relating to building and zoning)
restricting, regulating, prohibiting or relating to occupancy,
use and enjoyment of the land, dimensions, subdivision,
environmental protection, or violations/enforcement
thereof, or police powers (UNLESS covered under
insuring clause, which covers if notice is recorded before
date of policy).
Same.
Rights of eminent domain (UNLESS covered by insuring
clause, which covers if notice is recorded before date of
policy ).
Same.
September 2007 | 8
Mortgage Banking & Consumer Credit Alert
Defects, liens, encumbrances, adverse claims and other
matters (i) created, suffered, assume or agreed to by the
insured claimant; (ii) not known to the company, not
recorded but known to the insured and not disclosed in
writing; (iii) resulting in no loss or damage; (iv) attaching
subsequent to date of policy (although this does not limit
certain coverages that have post-policy elements); or (v)
resulting in loss that would not have been sustained if
insured had paid value for the insured estate.
Same.
Claim under bankruptcy or other creditor’s rights laws
that the insured mortgage is a fraudulent conveyance or
preference UNLESS covered under insuring clause (which
covers such matters occurring before the insured vesting
transaction).
1970 policy does not have creditor’s rights
exclusion; this was one of the main objections to
the 1992 policy (although insurers believe these
matters were not covered under 1970 policy in
any event). With 2006 policy, would need to
request endorsement to delete creditor’s rights
exclusion. This is frequently available for routine
purchase transactions.
Lien for taxes and assessments imposed between
date of policy and recording of insured deed.
Not in 1970 policy; added as exception to new
gap coverage in 2006 policy.
Schedule A
Schedule A
Same.
Same.
Schedule B
Schedule B
Same.
Same.
Conditions
Conditions
New definitions included for Amount of Insurance, Date
of Policy, Entity, Title.
Expanded definition of Insured, including successors in
interest by operation of law (e.g., heirs & devisees) (same);
holder of transferable electronic record; successors of
entity conversions, dissolutions, mergers, reorganizations;
grantee under deed given without consideration to affiliates
and subsidiaries (intended to eliminate Fairway issue).
(Note: all defenses are preserved against other insureds.)
Only includes successors by operation of law.
Need to endorse to voluntarily transfer to
subsidiaries or trusts.
Continuation of Insurance.
Similar.
September 2007 | 9
Mortgage Banking & Consumer Credit Alert
Notice of claim: insured to give prompt notice of litigation,
knowledge of claim or rejection of title as unmarketable.
Coverage is reduced to extent that failure to give prompt
notice prejudices title co.
Equivalent.
Proof of loss; duty to cooperate: Specifies details for proof
of loss; includes duty to make books and records available;
requires insured claimant to submit to examination under
oath. Ninety day period deleted but cooperation is more
onerous on insured than 1970 policy.
Includes requirement to give proof of loss within
90 days after loss is determined. Details on proof
and cooperation not included.
Defense/prosecution of actions.
Equivalent.
Option or pay or settle.
Equivalent.
Extent of liability: includes new provision that if title
co. defends/prosecutes and is unsuccessful, amount of
insurance is increased by 10% or insured has right to have
loss determined either as of date or claim or date settled
and paid.
Equivalent, except does not include bump
up in damages if title co. does not settle and
unsuccessfully pursues litigation. (Note: does not
include co-insurance provision in 1992 policy.)
Limitation on liability, reduction in insurance, termination
of liability.
Equivalent.
Payment of loss within 30 days after definitely fixed.
Same.
Amount of insurance reduced by amounts paid to insured
mortgagee.
Same.
Not included.
Apportionment: If policy covers more than one
parcel and loss affects less than all, title co. can
pay on pro rata basis unless agreed value for
each parcel established by endorsement at date
of policy.
Title co. rights of recovery after settlement and payment:
title co. has subrogation rights but cannot exercise until
insured has recovered its losses.
Similar.
Arbitration: requires arbitration under ALTA rules for
policies of $2 million or less. (AAA dropped its rules for
title insurance disputes.)
Arbitration not included in 1970 policy and was
objectionable feature for many lenders under
1992 policies (although only for policies of $1
million or less, which eliminated most commercial
policies). Endorsement can be requested to delete
arbitration requirement.
September 2007 | 10
Mortgage Banking & Consumer Credit Alert
Policy is entire contract: provides for incorporation of
endorsements (which don’t modify policy, extend date or
increase amount unless expressed) so this language won’t
appear in endorsements.
Choice of law and forum is state where land is located.
Not included.
Reminders When Using 2006 Owner’s Policy:
„
You need to request deletion of creditor’s rights exclusion and affirmatively insure creditor’s rights risk through
ALTA Endorsement 21-06.
„
You need to request deletion of arbitration condition if policy is $2 million or less.
This article first appeared in the September 2007 issue of The Practical Real Estate Lawyer.
September 2007 | 11
Mortgage Banking & Consumer Credit Alert
K&L Gates’ Mortgage Banking & Consumer Finance practice provides a comprehensive range of transactional,
regulatory compliance, enforcement and litigation services to the lending and settlement service industry.
Our focus includes first- and subordinate-lien, open- and closed-end residential mortgage loans, as well as
multi-family and commercial mortgage loans. We also advise clients on direct and indirect automobile, and
manufactured housing finance relationships. In addition, we handle unsecured consumer and commercial
lending. In all areas, our practice includes traditional and e-commerce applications of current law governing
the fields of mortgage banking and consumer finance.
For more information, please contact one of the professionals listed below.
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September 2007 | 12
Mortgage Banking & Consumer Credit Alert
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DIRECTOR OF LICENSING
Washington, D.C.
Stacey L. Riggin
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Washington, D.C.
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K&L Gates comprises multiple affiliated partnerships: a limited liability partnership with the full name Kirkpatrick & Lockhart Preston Gates Ellis
LLP qualified in Delaware and maintaining offices throughout the U.S., in Berlin, and in Beijing (Kirkpatrick & Lockhart Preston Gates Ellis LLP
Beijing Representative Office); a limited liability partnership (also named Kirkpatrick & Lockhart Preston Gates Ellis LLP) incorporated in England
and maintaining our London office; a Taiwan general partnership (Kirkpatrick & Lockhart Preston Gates Ellis) which practices from our Taipei
office; and a Hong Kong general partnership (Kirkpatrick & Lockhart Preston Gates Ellis, Solicitors) which practices from our Hong Kong office.
K&L Gates maintains appropriate registrations in the jurisdictions in which its offices are located. A list of the partners in each entity is available
for inspection at any K&L Gates office.
This publication/newsletter is for informational purposes and does not contain or convey legal advice. The information herein should not be used
or relied upon in regard to any particular facts or circumstances without first consulting a lawyer.
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and with our regular newsletters, which may be of interest to you. We will not provide your details to any third parties. Please e-mail london@
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©1996-2007 Kirkpatrick & Lockhart Preston Gates Ellis LLP. All Rights Reserved.
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