WFG does not issue CPLs to lenders or any other party for the acts of a non-agent with two exceptions:
- Illinois - There is a quasi-insurance type escrow company called an “independent escrowee”. Under the statute, the IE has to meet the same financial requirements as a title insurance underwriter ($1,000,000 in liquid assets/reserves) and they are not required to issue CPLs like an underwriter does for their agents. There’s only 1 IE in Illinois and it’s owned by a WFG agent. WFG issues CPLs for the IE pursuant to a vendor’s services agreement that allows WFG to audit the IE’s accounts, etc.
- Approved Attorneys in states where that’s custom/practice pursuant to a vendor’s services agreement.
WFG could arguably issue a CPL pursuant to a vendor’s services agreement, but there’s not a lot of upside for WFG to do so.
In addition to the above, there may be regulatory issues in some states that would prevent WFG from issuing a CPL on behalf of a non-agent.
