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2/19/2014
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Title Company Ethics 2014
Stewart Title Guaranty CompanyJohn F. Rothermel, III
Senior Vice PresidentRegional Underwriting Counsel (SW Region)
Senior Underwriter
For Ethics Credit only please email password provided at the end of this webinar, attendees names, and TDI License numbers (if you have one) to [email protected] for certificates (please do this as soon as possible and make sure the correct spelling of the name(s) is included as to how it should appear on the certificate).
Because there are 2 webinars this week, in order to ensure the timely processing of your certificate, please include “Ethics Webinar” in the subject line of your e-mail.
Attorneys NO CLE credit is available for this webinar. Send to your training administrator if applicable.
Title Company Ethics 2014February 19, 2014
2/19/2014
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Title Company Ethics 2014
Stewart Title Guaranty CompanyJohn F. Rothermel, III
Senior Vice PresidentRegional Underwriting Counsel (SW Region)
Senior Underwriter
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Fiduciary ResponsibilitiesOf The Title Company
a. It’s someone else’s money
b. Audits
c. Bonds
d. Guaranty Association
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Somebody Else’s Money• MINIMUM STANDARDS, SPECIFIC INSTRUCTIONS AND REPORT
FORMS FOR AUDIT OF TRUST FUNDS REQUIRED OF TEXAS TITLE INSURANCE AGENTS, DIRECT OPERATIONS, TITLE ATTORNEYS, AND ATTORNEYS LICENSED AS ESCROW OFFICERS
• The objective of such audit is to determine that the escrow agent maintains adequate trust fund accounting records and that the financial statements contain no material misrepresentations.
• Confirmations shall be made of individual guaranty file accounts, accounts where funds have not been fully disbursed, and escrow bank accounts. Confirmation of all escrow bank accounts is mandatory.
• Escrow receivables are the responsibility of the escrow agent and constitute shortages in the account which are deemed to be violations of 2651.151 et seq. and 2651.202 et seq. Texas Insurance Code.
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Bonds Under Section 2651.101 • Every person, firm, association, or corporation which has been licensed
as a title insurance agent or direct operation shall make, file, and pay for a surety bond with a corporate surety company authorized to write surety bonds in this state, payable to the State Board of Insurance in the sum of the greater of Ten Thousand Dollars ($10,000) or an amount equal to ten percent (10%) of the gross premium written by the agent or direct operation in accordance with the latest statistical report to the Board, but not to exceed One Hundred Thousand Dollars ($100,000).
• Covers acts of fraud, dishonesty, theft, embezzlement, or willful misapplication on the part of a title insurance agent or direct operation, or which may result to the Board due to administrative expenses incurred in a receivership.
Other Bonds and Capitalization
• Part of the Agency Solvency reforms enacted beginning in 2009 and finally adopted effective Sept.1, 2014 is a requirement that an agent prove its capital based on the largest county in which it does business. The agency must be able to proof its assets exceed ($150,000 in the largest counties in Texas.
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Other Bonds and Capitalization
• Depending on the number of years licensed, the agency must either prove its capitalization immediately for a new agent or up to nine years for long-term agents. See our various materials on stewarttexas.com and vuwriter.com for details.
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Other Bonds and Capitalization
• One way to reach the minimum capitalization is to place a surety bond for the full amount of the required amount into the custody of the TDI or
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Other Bonds and Capitalization
• by using Form T-S2 to meet the requirements of Administrative Rule S.1. If creating a Solvency Account, the agency must deposit into the account a portion of the agent’s portion of the premium (the greater of 1% or $5) from each transaction. Deposits must be made to the Solvency Account quarterly (within 31 days of the end of each calendar quarter). There is no set deadline for reaching the required level of funds (required by Sec. 2651.012).
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Guaranty Association• Chapter 2602 Ins. Code applies to all title insurance (direct and reinsurance)
written by title insurance companies authorized to do business in this state and doing business under and regulated by the provisions of this Title 11 and to trust funds or escrow accounts of title insurance companies or title insurance agents authorized to do business in this state.
• "Covered claim" is an unpaid claim (iv) against trust funds or an escrow account of an impaired agent which arises due to a shortage of those funds or in that account.
• A "covered claim" under Subparagraphs (i) and (iii) of this paragraph shall be limited to the lesser of $250,000 per claimant or $250,000 per policy.
• "Covered claim" shall also not include any shortage of trust funds, shortage in an escrow account resulting from the insolvency of a financial institution.
• (7) "Agent" includes a title insurance agent as defined by 2501.003 of this code, a title attorney as defined by 2552.002 of this code, and any insurer's direct operation, wholly owned subsidiary, or affiliate which performs the services usually and customarily performed by a title insurance agent.
• (13) "Trust funds" or "escrow account" includes those accounts which are subject to annual audit pursuant to 2651.015 et seq. of this code.
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Guaranty Association
• The powers of the guaranty association have been expanded by the Legislature over the years since its creation.
• Originally it applied only to underwriters that became insolvent ( Commercial Standard, Elliot and Waldren and Title USA) but was later expanded to agents.
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Guaranty Association
• The guaranty association has the power to level a guaranty fee to provide the funds to audit and administer insolvent agents (reduced to $0 effective 1-1-2014) and to assess underwriters to provide claims handling funds if another licensed underwriter fails (recently enacted at $1.80 per policy effective 1-1-2014.
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Plan For Ceasing Business
• One of the solvency pieces recently implemented is the requirement that each agency provide to the TDI its plan for ceasing business … should that ever occur.
• Another requirement is that all agency office leases provide the underwriters and TDI with access to office space should the agent cease to do business.
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Change in Definitionof Insolvent
• The original solvency legislation required an agent to have escrow account shortages before the Guaranty Association could step in. The failure of United Title of Texas’ parent company with no escrow shortages required a change so that ceasing to do business allows TTIGA to step in.
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Benefits of Being Neutral
Innocent Stakeholder Defense• Attorney fees come from
the escrow amount.
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Staying Neutrala. Don’t take sides
b. Don’t disclose confidential informationi. Privacy rulesii. Requiring a
subpoena1. What if it’s the FBI,2. or the IRS,3. or another realtor?
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Earnest Money
The TREC Contracti. Provisionsii. Title company not a
partyiii. Receipt for contract
and fundsiv. Protection (?) from
disputes
Other Contractsi. READ
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TREC Contract Paragraph 18
• The earnest money is deposited with escrow agent with the understanding that escrow agent is not:a. a party to this contract and does not have any liability
for the performance or nonperformance of any party to this contract,
b. liable for interest on the earnest money and c. liable for any loss of earnest money caused by the
failure of any financial institution in which the earnest money has been deposited unless the financial institution is acting as escrow agent.
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More on TREC Paragraph 18
• If both parties make written demand for the earnest money, escrow agent may require payment of unpaid expenses incurred on behalf of the parties and a written release of liability of escrow agent fromall parties.
• If one party makes written demand for the earnest money, escrow agent shall give notice of the demand by providing to the other party a copy of the demand.
• If escrow agent does not receive written objection to the demand from the other party within 30 days after notice to the other party, escrow agent may disburse the earnest money to the party making demand reduced by the amount of unpaid expenses incurred on behalf of the party receiving the earnest money and escrow agent may pay the same to the creditors.
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Do You Feel Brave?
• If escrow agent complies with the provisions of this paragraph, each party hereby releases escrow agent from all adverse claims related to the disbursal of the earnest money. Escrow agent's notice to the other party will be effective when deposited in the U.S. Mail, postage prepaid, certified mail, return receipt requested, addressed to the other party at such party's address shown below. Notice of objection to the demand will be deemed effective upon receipt by escrow agent.
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It’s In Its Own Box!!Keeping It There Is The Trick!!!!!
RECEIPT• Receipt of [ ] Contract and [ ] $ ______ Earnest
Money in the form of _______is acknowledged.• Escrow Agent: ____________Date: _________• By:_________________• Address• Telephone: ( )• City, State Zip• Facsimile: ( )
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Escrow Agreements
• What can we escrow for?i. Repairs?ii. Incomplete construction?iii. AJ’s?iv. Title disputes?
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Insuring Around Must Be Considered
Procedural Rule P-11
• Insuring around-1. defined
2. can be a crime!
3. things to look for
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More On P-11
• Mechanic’s liens• Indemnity Agreements• Subordinate Liens and Leases• Federal Estate and State Inheritance Taxes
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P-11 Definition
• 'Insuring Around' is defined as the willful issuance of a title binder or title insurance policy showing no outstanding enforceable recordedliens while the Title Insurance Company knows that in fact a lien or liens are of record against the real property.
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Express Insurance Ok
• A title insurance company knows that an outstanding enforceable recorded matter exists if it determines that the matter is valid and enforceable based on the examination of the title pursuant to which the title binder or title insurance policy is issued. In its discretion, the title insurance company may determine the insurability of title and those matters which it considers to be insurable under the title binder or title insurance policy insuring around enforceable recorded liens shall be prohibited except as allowed by regulation.
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Escrow for Repairs
Agreed To In Writing
• Relatively short time—30 to 60 days is suggested
• Released with written approvalof lender, buyer , seller and contractor– Can provide that a document
from buyer and contractor is enough
• Not at interest normally
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Not A Good Idea ToEscrow For AJ’s
• Can execute without warning
• Creditor owns the property
• Not necessarily limited to value of AJ– Can ask for value of the property
• People may hate each other by the time we come along
• Might be ok with consent of the creditor
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When Is It Not Insuring Around?
• P-11b “Insuring Around” shall not include the issuance of a title insurance policy or binder under the following circumstances.
• Where funds are in escrow to pay same, and a recordable release is forthcoming and will be filed for record in the ordinary course of business.
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P-11 and Estate Taxes(9) In instances where federal
estate taxes and state inheritance taxes have not been paid, but the title insurance company …
b) Requires sufficient money or other securities to pay estate and inheritance taxes to be left in escrow with it pending payment of such taxes, or pending the receipt of waivers of lien from the taxing authority or authorities.
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Subordinate Liens and LeasesUnder P-64
• When issuing a Mortgagee Policy insuring the validity and priority of a lien, the issuer shall not be required to itemize liens and leases that affect the title to the estate or interest, which are subordinate to the lien insured, either by express subordination or by operation of law, unless requested to do so in writing by the insured in which case paragraph 4 of Schedule B may be deleted, and the subordinate lien(s) and lease(s) shall be excepted in Schedule B and the Company may insure therein such lien(s) and lease(s) are subordinate.
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Subordinate Liens (part 2)
• When insuring that a lien or lease is subordinate to the lien of the insured mortgage, the Company shall state: "Company insures the insured against loss, if any, sustained by the insured under the terms of the Policy if this item is not subordinate to the lien of the insured mortgage.
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Mechanic’s Liens
• How much cash do you need?– Known liens-- 125% to 150% of the stated amount
– Unknown Liens —• Proceeds• Retainage• % of the job
– $ held at closing to buy releases is also in escrow re: P-11
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More on Mechanic’s Liens
• How long should you keep the money?– Minimum– until the end
of the lien filing period for unknown liens
• Usually used when P-8 exception isn’t used
• For known liens, shorter of statute of limitations for filing suit or 6 months is a good rule of thumb
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The Agreement Itself
• Who draws
• Whose form (see sample attached as exhibit)
• Mechanic’s
• Good funds or goods or money or something else
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Critical Elements
1. Who’s in control2. Bank insolvency3. At interest
a. taxpayer id numberb. who picks the bankc. access to funds
4. Is there a branch of that bank in your town
5. Do you need collateral for the agreement
Financial Statements LikelyTo Be Required
• Because of the large number of claims from 2008 to 2012 due to mechanic’s liens, in many cases STG is requiring the owner and the contractor to indemnify us and provide financial statements.
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What Is Required On The Financial Statement?
• In a word: money.• Many builders and developers are asset rich and
cash poor. From a tax perspective, that makes sense, but when we are being asked to rely on a person’s assets, his Picasso collection, and his Bentley, and his houses in France and Italy don’t help much.
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What Is Required On The Financial Statement?
• A person called upon to make good on an indemnity is not particularly likely to voluntarily sell an expensive painting just to satisfy the title company. Of course his Bentley is probably homestead exempt and how do we seize foreign real estate.
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What Is Required On The Financial Statement?
• We need to see real cash assets or cash equivalents (money market accounts, etc.). Good will is worthless to us as is ownership in various LLCs.
• Speaking of LLCs, if the entity offering the indemnity is a single purpose entity we will need financials on the various owners upstream until we reach a general purpose entity or solvent individual.
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Letters Of Credit
a. Form
b. Who draws
c. How long good for
d. Unconditional
e. Put in on your calendar! Don’t let a LOC expire!!!!!
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Letter Of Credit (part 1)
Example Letter of Credit Form 1(Name of the Bank)(City - State)(Month-Day-Year)
IRREVOCABLE LETTER OF CREDITLetter of Credit No.Stewart Title Guaranty Company(Address)(City, State)
Gentlemen:
We hereby establish our Irrevocable Letter of Credit in your favor of __________________, available by your drafts drawn at sight on _________________________________________ for any sum or sums not exceeding a total of __________________________________ ($______________ ), and accompanied by:
NO DOCUMENTATION REQUIRED.
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Letter Of Credit (part 2)
• Except as otherwise stated herein, this credit is subject to the Uniform Customs and Practice for Documentary Credits ( _____ Revision), International Chamber of Commerce, Brochure No. __________________ ).
• The amount of each draft negotiated, with the date of negotiation, must be endorsed hereon by the negotiating bank, and any draft presented to us shall constitute a warranty of the negotiating bank that such endorsement was effected.
• All drafts drawn under this credit should bear the clause “Drawn under ______________________________________________________ Irrevocable Letter of Credit No. ______________________ dated ____________________________.”
• We hereby agree with you that all drafts drawn under and is honored upon presentation to ____________________________________________ together with this letter of credit on or before __________________________________________.
• Bank
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Education For Managers
• Another part of the solvency legislation and regulations is required education for escrow officers, title agents and the day to day managers.
• 2651.204 for continuing hours for escrow officers and 2651.0021 for managers (before license issuance).
• 1 hour of ethics is required after 1-1-2014.
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P-53 Update
• It Just Ain’t NEW
• Art. 9.30 Insurance Code and it’s predecessor 9.22, have been around in one form or another since the 1920’s.
• Word is that a certain Maco Stewart delivered the first version of an insurance code to the department and it contained 9.22.
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Quid Pro Quo
• It is absolutely clear and has been for 80+ years, that giving ANYTHING in return for a SPECIFIC title insurance transaction is ABSOLUTELY PROHIBITED.
• “I will give you the order for this house, if you will pay for the open house the next 2 weekends” is a quid pro quo has always been prohibited.
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Bulletin 23 – From 1951
• Joe Gibbs Commissioner of property casualty companies said, “ It should not be difficult to determine whether or not a particular course of action constitutes the giving of a premium rebate or discount…”.
• The bulletin then addresses the relationship of the attorney to the title company.
• It looks to a 1948 letter in which attorneys are allowed to be paid a fee for work done for the title company.
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Bulletin 23 (part 2)
• Mr. Gibbs then looks at several specific examples:
– No branch offices that are not run by title company personnel. Violates the licensing requirements.
– Branch office run by title company employees who send deals and premium to agent that deducts a flat charge returns the balance = rebate.
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P-53 Generally
• TDI and TLTA had tried 3 times previous to the passage of P-53 to get a workable rule. All 3 efforts were abysmal failures.
• Commercial companies fought with each other and with rural agents to a stand-still.
• On committee of all aspects of real estate came up with a plan but committees were abolished before giving the recommendation.
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P-53 Generally
• It is obvious that some people were making a fine living by traveling the country telling real estate agents how to get title companies to pay for their needs.
• Open houses
• Printing brochures
• Fancy trips
• All of their advertising
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P-53 Generally
• Art. 9.30 (now 2502.051) prohibits quid pro quo • STG added 9.30b6 (now 2502.055): legal promotional
and educational activities that are not conditioned on the referral of title insurance business.
• Commercial free speech.• Right of a company to exercise the same free speech
rights as an individual under the 1st amendment to the US Constitution.
• In 2011, TDI convinced Legislature to remove “legal” from 2502.055.
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Removing “Legal”
• TDI asked for legal to be removed because they said that anything not conditioned on the referral of business was already legal and anything that was conditioned on the referral of business was already NOT legal. So legal added no value and confused the issue.
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Pre-P-53
• Printing of all of the realtor’s brochures and other things. Fancy trips. Fancy meals and events. Expensive sporting events. All done to get business.
• Rate hearing: throw out or cap expenses in excess of a certain amount to keep rebates from affecting the rates and drive out the ability to pay rebates.
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Bulletin 158
• Created in 1996.• Prohibits controlled business companies that are
not licensed (and taking some of the business risk).
• Allows most forms of entities owning title companies.
• Prohibits a laundry list of activities.
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Prohibited things:• Recreational activities or trips• Open houses or social functions• Christmas or other gifts• Providing people, stuff or office space for agent• Property reports, farming reports or brochures’• Renting space at inflated costs• Prizes at educational or promotional events• Free meals at seminars
Is any of this sounding familiar? Well it should.
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Bulletin 158
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Bulletin 158
• Most activity ceased for a while.
• The Department didn’t enforce the bulletin.
• They have questionable enforcement validity.
• Questions arose over commercial free speech.
• Producer’s whined and cried.
• Title companies went back to business as usual.
• Traveling seminar producers continued their “hands out” training.
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After Bulletin 158
• Created print shops• Costing upwards of $20,000 a month to produce the
flyers, etc. for realtors EVEN THOSE THAT DIDN’T USE US!
• Tickets to sporting events• Fight night tickets• Trips• Paid for advertising• Generally costing millions a year
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P-53
• STG worked with TLTA to form a committee of all kinds and sizes of title companies to draft a workable rule with stated large penalties to discourage realtors and others from even asking for hand outs.
• Committee drafted, TLTA approved, TDI approved and the rule went into effect.
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P-53
• The title industry responded to the rule that we had asked for in its usual sterling way.
• We began immediately calling TDI and asking them to approve something that was a violation on its face but which we had been doing for years and asking for permission to keep doing it.
• Overwhelmed the staff. Conflicting answers. Told by commissioner to stop. Just enforce violations.
• Dozens of complaints filed by competitors have given the staff the ammunition to say that rebating is rampant and that rates are WAY TOO HIGH.
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P-53
• The main thing to take away with you today is: No title company can pay for or subsidize any stuff or activities of any current or proposed customer.
• Who is covered by the rule? All title insurance companies, title insurance agents, direct operations and all escrow officers and all of the officers, directors, agents, employees, members of their immediate families of the title companies. All of these people are called Authorized Persons.
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P-53
• Who else is covered by the rule?
• Producers of title insurance business. This means all real estate brokers and agents; all lenders, mortgage companies and mortgage brokers, all builders and developers, all attorneys and architects and their officers, directors, agent, or member of their immediate family and people who own or control or is owned or control by any of them.
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P-53
• They can’t, directly or indirectly pay for or subsidize advertising or promotional materials or activities of a Producer. Directly means from one of the people in the list above. Indirectly means giving the money to an unrelated third party for them to pay the producer.
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P-53
• Individually or jointly advertising any particular property or group of properties when the activity subsidizes the business or promotional activity of the Producer.
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What Is Joint Advertising?
• Providing, paying for, subsidizing or sponsoring:
– Signs advertising a property or group of properties, electronic or hard copies of advertising media describing, promoting or advertising a property or group of properties;
– Boxes with materials about the property or group of properties.
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What Else Is Joint Advertising?
• Providing or furnishing prizes, food , beverages, gifts, decorations, entertainment of professional services.
• Providing or paying for any advertising medium that subsidizes the business, products, services or promotional activities of the Producer.
• Comment: This section deals with anything that assists the Producer in his business activities. It would include private newsletters, booklets, business cards and stationary, signs for vehicles, flyers, handouts and listing packages.
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What Else Can’t An Authorized Person Do For A Producer
Provide or pay for:
• Furnishings, office supplies, electronic or hard copy documents or media, computer hardware or software, telephones or telephone systems, copiers or fax machines, office equipment, vehicles or administrative, management or staff services, rental or office facilities.
Comment: Most of the things in this list have the normal meaning. Administrative, management or staff services would include secretarial services, book keeping or accounting or escrow services, payroll or human resources services, marketing staff and courier or delivery services, audit services and data process or informational services.
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What Else Can’t I Do?
• An Authorized Person cannot provide listing packages or do printing for anyone except for themselves. They can produce and distribute promotional and education materials about title insurance, loans, and mortgages, real estate matters generally and laws and legislation provided the name of the Authorized Person is set out prominently on the cover and first page of the materials. The materials may not contain the name or symbol of a Producer.
Comment: This section effectively eliminates the ability of an Authorized Person to jointly advertise with a Producer. It also eliminates the ability of the Authorized Person to do printing for a Producer. The Authorized Person can provide educational matters about the title business and related topics but there can be no co-branding.
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But Wait A Minute
• The commissioner issued a directive to the enforcement section of TDI that simply providing generic material such as a listing package showing information about a neighborhood to a realtor with no expectation for a specific title order was not a violation.
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Can I Give A Friend A Gift? Can I Give A Customer A Thank You Gift?
• The short answer is no.• But, in reality, if the person is really a friend, not strictly a
customer you can probably give them a birthday or holiday gift of the same reasonable value you give to friends not in the real estate business.
• A customer can probably have a reasonably priced meal, or a writing pen with your name on it. Not stocks, bonds, expensive trips, gold or silver.
• Then again, if the person is really a friend, why would you have your company pay for a gift?
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Are There Penalties For ViolatingThis Rule?
• Yes. The Department can levy a civil penalty up to $10,000 per violation and for each day of the violation. An Authorized Person can lose their license or certificate of authority for later or repeated violations.
Comment: The Department also can levy a fine up to 3 times the value of the material.
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The Last Revisions
• A title company and its employees may:
a. Join a trade association and voluntarily participate in its activities as long as the activity would not be ordinarily performed by paid staff of a trade association.Comment: what the heck does that mean???
b. Purchase advertising at market rates in events, activities or publications of a trade association or producer other than the events etc. prohibited in 1d2.Comments: These are the normal P-53 things discussed above.
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FAQs
• Title companies can deliver by courier or express or regular mail.
• Items or materials related to the transaction to a producer or the producer’s client.
Comment: Let’s see, I’ll bet this means commission checks, ‘eh?
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FAQs
• Can we sponsor a sports camp for producer’s children like we always have?NO. In fact former title division head Rob Carter always uses this one as an example of the evils that P-53 is fixing.
• May a title company host its own annual party or open house to advertise its own business, but not more than one party per office per year.Yes. De minimis standards will apply. The invitation list should not be restricted to producers.
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FAQs
• Can a title company avoid P-53 by having a party with door prizes at a title company employees home?No. The rule speaks of directly or indirectly and at home is indirectly.
• Can a title company give out commitments to get business?No. Violates P-18 (no bona fide order) and if it has value, violates P-53.
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FAQs
• Can an agent provide “Lots of Food and Drink”?
We planned on 400 attendees at our open house and X catered this event for $3575.00. The caterer stated they served over the 400 attendee estimation. We purchased soft drinks, water, wine and beer ourselves for $839.00. The total cost per attendee would be about $11.00.
Comment: This is a di minimis cost and would normally be fine.
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FAQs• Giving away pumpkins and prizes for contest winners?
We purchased fifteen pumpkins at a cost of $10.00 per pumpkin from X United Methodist Church with the proceeds benefiting a children’s charity. These pumpkins were distributed to anyone who wished to carve a Jack-O-Lantern. State Representative Y judged the contest and while the winners were recognized, no prizes were awarded.
Comment: Again we did nothing wrong. Di minimis expense. No prizes. No quid pro quo.
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FAQs• If the attorney that owns their company and is not a fee
attorney can entertain her customers and charge his P&L rather than the title company’s P&L. She says X is doing this and seems to be getting away with it. Would this be a P53 violation?
• P-53 1b defines an affiliate as anyone that owns or is owned by or is under common ownership with an authorized person. So, since X owns the title company (an authorized person) and the law firm (an affiliate), then the rule applies to there as well.
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FAQs• Can a title company waive escrow fees? It depends.
• You must be able to economically justify why you are waiving the fees?
• A builder whose buyers typically use the same mortgage company and the builder and the lender always have the same requirements? Probably ok.
• All deals over $x? Probably ok since the people buying at the high end are more sophisticated and closing takes less time and there are fewer issues with payoffs, etc.
• As part of a realtor’s sales promotion? No.
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FAQs
• Can the spouse of a title company employee give something or do something that the employee can’t?No. A spouse is part of the immediate family of the title company employee and is indirectly covered by P-53.
• What can we give a realtor to help them market a property? One copy of the vesting deed, deed of trust and restrictions and plat. Multiple copies of those things, no.
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FAQs• My best builder client wants me to participate in paying
for his sign at his new subdivision. Can I?
It is a matter of percentages and what you say.
Commercial free speech and (9.30 now 2502.051 et seq.) allows you to advertise yourself. So if your name address and phone are included and you have 10% of the sign and pay for 10%, you are probably ok.
Paying for ½ and getting just your name on the bottom corner probably would not be ok.
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Final Thoughts
• Avoid anything that is a quid pro quo… a contract for a gift or service.
• Avoid paying for a customer’s business expenses, like cards, rent, cars, giveaways.
• Keep records of expenses for association or groups to prove di minimis amounts.
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THANK YOU!
For Ethics Credit only, please e-mail the password, attendees names, and TDI License number (if you have one) to [email protected] for the certificate (please do this as soon as possible and make sure the e-mail includes the name(s) as it should appear on the certificate). Please be aware that due to TDI's strict policies on issuing credit, you must pay close attention to the password given at the end of the webinar as we are unable to give it out once the presentation has been terminated off of Webex.
Please include “Ethics Webinar” in the subject line of your e-mail to ensure timely processing of your certificate.
Attorneys NO CLE credit is available for this webinar.
Questions/Comments? Email [email protected]
Please visit www.stewarttexas.com for the presentation materials within 5 business days of the webinar.