The Federal Housing Finance Agency’s Title Acceptance Pilot remains one of the most closely watched developments in the title industry. Announced in March 2024, the pilot has expanded modestly while continuing to draw significant debate from industry groups, state regulators, and members of Congress.
Here’s where the pilot stands and what it means for title professionals.
What the Pilot Does
The Title Acceptance Pilot allows lenders to sell certain refinance loans to Fannie Mae without obtaining lender’s title insurance or an attorney opinion letter (AOL). It applies to a narrow category of transactions: refinances with loan-to-value ratios below 80%, where the borrower already holds clear title and there are no prior liens or encumbrances.
Instead of requiring title insurance from a state-regulated insurer, the pilot uses an automated title review process to assess risk. If the automated review determines that title risk is low, the lender pays Fannie Mae a $75 fee per transaction to cover potential title defects, and no additional independent verification is required.
Homeowners can still choose to purchase their own title insurance policy or AOL independently. The pilot only affects the lender’s title requirement, not the borrower’s coverage options.
What’s Changed Since Launch
The pilot has evolved since its initial rollout.
In July 2025, Westcor Land Title Insurance Company joined the pilot as a second vendor alongside Doma Title Insurance, partnering with X1 Analytics and Mortgage Connect to deliver an automated, title insurance-backed product within the pilot framework. Westcor is the nation’s largest independent title insurance underwriter, and its entry signaled broader industry engagement with the program.
FHFA leadership has also changed. Bill Pulte replaced Sandra Thompson as FHFA Director, and the pilot now operates under his oversight. Biannual updates on the pilot’s performance and scope are expected going forward, with the next rounds anticipated in early and mid-2026.
The pilot’s eligibility criteria remain narrow, limited to low-risk refinances in select geographic areas. There has been no expansion to purchase loans, which represent approximately 75% of the mortgage market.
The Case for the Pilot
Proponents argue the pilot addresses a real cost concern for homeowners.
Closing cost reduction. Federal estimates suggest the pilot could save homeowners $300 to $1,500 per refinance transaction by eliminating the lender’s title insurance requirement in cases where the borrower already holds clear title.
Low-risk scope. By limiting eligibility to high-equity refinances with no prior liens, the pilot targets transactions where the probability of a title defect is statistically low.
Consumer choice preserved. Homeowners retain the option to purchase their own title insurance. The pilot only removes the lender’s requirement, not the borrower’s ability to obtain coverage.
Industry and Regulatory Concerns
The pilot has drawn substantial pushback from title industry organizations, state officials, and members of Congress.
Consumer protection questions. The American Land Title Association (ALTA) has raised concerns that automated public record reviews cannot replicate the depth of expert title examination. ALTA has noted that a significant share of title claims involve issues that are not visible in public records alone, such as unrecorded liens, forgery, or identity fraud, and that removing professional title review from these transactions shifts risk in ways that may not be apparent until a claim arises.
State regulatory concerns. Fourteen state Attorneys General formally urged FHFA to terminate the pilot, arguing that title insurance has historically been regulated at the state level and that the pilot represents federal action in a domain traditionally governed by state oversight. The Attorneys General expressed concern about consumer exposure to title defects that automated systems may miss.
Congressional scrutiny. Members of the bipartisan Congressional Real Estate Caucus wrote to FHFA expressing concerns about the pilot’s impact on consumer protections and calling for a halt until the program received broader public input and vetting.
Market impact assessment. Analysts at Fitch Ratings and BTIG have suggested the pilot’s narrow eligibility criteria make it unlikely to significantly affect title insurer revenue or disrupt the broader industry. The limited scope has led some observers to question whether the pilot’s practical impact justifies the regulatory debate surrounding it.
What This Means for Title Professionals
Regardless of where one stands on the merits of the pilot, it raises practical questions for title companies, abstractors, and settlement agents.
Scope remains narrow. The pilot currently applies only to certain low-risk refinances, not purchase transactions. For the vast majority of closings, title search, examination, and insurance requirements remain unchanged.
The broader conversation matters. Even if the pilot itself has limited direct impact, it has opened a national conversation about the role of title insurance, the use of automated title review, and the balance between cost reduction and consumer protection. Title professionals should stay informed as the regulatory landscape continues to evolve.
Demand for accurate research isn’t going away. Whether a transaction requires traditional title insurance, an AOL, or falls under the pilot’s automated review framework, the underlying need for accurate property records, lien identification, and ownership verification remains. The method of risk assessment may change, but the quality of the data it relies on doesn’t become less important.
Capitol Lien’s real estate research, lien research, and court research services provide the accurate, thorough results that title professionals, lenders, and attorneys depend on, regardless of how the regulatory framework around title insurance evolves. When the integrity of the transaction depends on the quality of the search, the research has to be right.
This article is provided for informational purposes only and does not constitute legal or regulatory advice. Consult qualified legal counsel for guidance specific to your organization.
About Capitol Lien
Capitol Lien empowers real estate and title professionals with trusted public record research and due diligence services nationwide. With 35 years of experience, Capitol Lien specializes in fast, accurate property and title searches, lien reports, and document retrieval that help title agents, underwriters, and legal teams operate their businesses with confidence. The Capitol Lien team takes the hassle out of title research with local experts and innovative tools that make it easier to mitigate risk, stay on schedule, and keep your closings moving smoothly.
Learn more at capitollien.com. Ready to simplify your title research? Send your next order to Capitol Lien and experience the difference trusted diligence makes. Stay in touch with Capitol Lien on LinkedIn for industry updates and information. Reach out! contact@capitollien.com or 800-845-4077.
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