410/789.8400

Stewart Title Guaranty Company
609 Global Way - Suite 122
Linthicum Heights, MD 21090
410/789.8400
410/789.8407 fax

Date: July 12,2005
To: All Issuing Offices and Affiliated Companies
From: Stewart Legal Services
Re: Privacy of Personal Information of Consumers and Customers; Disposal and Updated Privacy Notice

Dear Associates;

Privacy Requirements

The Grahmm-Leach-Bliley Financial Services Modernization Act (G-L-B) protects the privacy of nonpublic personal financial information relating to consumers and customers (Customer Information). This law, and regulations, impose requirements upon title insurance companies and title insurance agents to protect the confidentiality of the nonpublic personal financial infonnation, and to retain adequate safeguards.

You may see these requirements by reviewing:

• Bulletin NL000IO3. This Bulletin discusses G-L-B and your obligations.
• Bulletin NL0000 160. This Bulletin discusses Safeguards Rules and other privacy issues. Information securing programs include safeguards used to dispose of nonpublic personal financial information.

Disposal Rule

Recently, the Federal Trade Commission (Fit) adopted Disposal Rules (at 16 CFR §682.l, et seq.) for proper disposal of consumer information by businesses. Consumer information means a consumer report or any document that “is derived from a consumer report.” This may include information in a lender package.

A business with consumer information must use proper procedures when disposing of the consumer information. The procedures must include reasonable measures to protect against unauthorized access to or use of the information. Examples of reasonable measures may include:

• Implement and monitor compliance with procedures that require burning pulverizing or shredding of paper containing consumer information so that it cannot practicable be read or reconstructed.
• Implement and monitor compliance with procedures that require destruction or erasure of electronic media containing consumer information so that it cannot practicably be read or reconstructed.
• Enter and monitor compliance with a contract with another company engaged in record destruction consistent with this rule. Due diligent investigation of the company could include review of an independent audit of the company’s operation, several rcrences or reliable sources, certification by a recognized trade association, review of security policies or procedures or other measures to determine competency and integrity.

Persons subject to G-L-B and the Safeguards Rule of Fit must incorporate proper disposal of consumer information into their information security programs. The above procedures are part of the SISCO security program, where applicable. You may wish to consider incorporation of similar procedures in your security program.

Modified Disclosure Forms

Attached in Exhibit 1 are modified Privacy Notices. These notices are not intended to replace state specific privacy notices in states such as California and Oregon. The revised Stewart Privacy Notice should be used elsewhere.

THIS BULLETIN IS FURNISHED TO INFORM YOU OF DEVELOPMENTS RELATING TO APPLICABLE LAW. OUR UNDERWRITING AGREEMENTS DO NOT AUTHORIZE OUR ISSUING AGENTS TO ENGAGE IN SEITLEMENTS OR CLOSINGS ON BEHALF OF STEWART TITLE GUARANTY COMPANY. THIS BULLETIN IS NOT INTENDED TO DIRECT YOUR ESCROW OR SETTLEMENT PRACTICES OR TO CHANGE PROVISIONS OF APPLICABLE UNDERWRITING AGREEMENTS.

References

Bulletins Replaced: None
Related Bulletins: NL0000IO, NL0000I6
Underwriting Manual: None
Exceptions: None
Forms: None