All Inwest Title Services, Inc. employees are responsible for promptly and seriously addressing any complaint made by a customer against Inwest Title Services, Inc. or its employees.

Agents receiving a communication from a customer (via phone, fax, e-mail, or in person) with a complaint must:

• Remain courteous at all times and, under all circumstances, refrain from engaging in argumentative behavior with the customer regardless of the nature of the complaint or the conduct of the customer.
• Completely and accurately document information pertinent to the complaint in writing.
• Escalate the call to an office manager or senior manager when:
  • It becomes clear the customer wishes to pursue a formal complaint, or
  • The employee feels unable to further assist the customer.
• Not confirm, discuss, or reveal the customer-specific information without confirmation of the caller’s identity as the customer in question or with a representative of the customer with appropriate written authorization.

If a formal complaint is to be filed, then the customer or the company employee taking the complaint must use the company’s online customer complaint form (see Section 32 of this manual) and the form must be filled out completely as possible.

Privacy

Federal privacy laws prohibit the release of borrower-specific information to anyone without the borrower’s expressed, written authorization or order of a court of competent jurisdiction documentation .

All formal complaints against Inwest Title Services, Inc. or its employees must be documented using the Inwest Title Services, Inc. Customer Complaint Form.
A log of consumer complaints shall be maintained that includes the following:

• Contact information for the Customer, including: name, address, phone number, email address.
• Details of the incident, including: date of incident, subject of the incident, detailed description of
  incident, transaction information, names of people involved, and name of lender or underwriter (if
  applicable).
• Actions taken by Inwest, including: assigning a priority level, open date, closed date, actions
  taken, and final resolution.

The single point of contact on all formal Customer Complaints shall be Inwest’s In-House Counsel.

Violation of Policy

Failure to adhere to all requirements stipulated in this policy and all related documents may result in
disciplinary actions, up to and including:

• Immediate removal of any applicable hardware/software/access to the Inwest Title Services, Inc. computer network or business systems
• Formally reporting the incident to Inwest Title Services, Inc. senior management
• Termination of employment
• Any other action deemed necessary by Inwest Title Services, Inc. senior management