STATE OF WASHINGTON

OFFICE OF THE INSURANCE COMMISSIONER

In The Matter of

ORDER NO. 14-0249

THE LAND TITLE COMPANY OF PEND
OREILLE COUNTY. INC.,
Licensee.
To:

WAOIC#
FEIN

23084
91-1468632

ORDER REVOKING LICENSE

The Land Title Company of Pend Oreille County, Inc.

309 S. Washington Avenue
P.O. Box 477
Newport, Washington 99156
judy@landtitlecompany.nel
IT IS ORDERED AND YOU ARE HEREBY NOTIFIED that your

Washington State title insurance agent's license is REVOKED, effective Januar>' 12.
2015, pursuant to RCW 48.17.530 and RCW 48.17.540(2).
THIS ORDER IS BASED ON THE FOLLOWING:
1.

The Land Title Company of Pend Oreille County, Inc. ("Land Title" or

"the Licensee") held a Washington resident title insurance agent's license. WAOIC
-23084, licensed February 25, 1980, until it expired on August 16, 2014. The Office of
the Insurance Commissioner ("OIC") opened its investigation into this matter in
Februar>' 2014. Pursuant to RCW 48.17.530(3), the Washington Insurance
Commissioner retains authority to revoke this license despite its expiration, because
Land Title was under investigation for the below-listed violations of Title 48 RCW at
the time of the expiration.

ORDER REVOKING LICENSE

ORDER NO. 14-0249
1179721

State of Washington
OfTice of Insurance Commissioner
5000 Capitol Blvd.
PO Box 40255
Olympia. WA 98504-0255

2.

The Insurance Commissioner received a complaint from First American

Title Insurance Company ("First American") on February 10, 2014, advising that First
American had terminated Land Title's appointment for cause.
3.

According to First American, its auditors found that Land Title had

consistently failed to properly reconcile its escrow accounts, made overdrafts in its
escrow accounts, and failed to promptly account for and pay fijnds to the persons entitled
thereto.
4.

First American discovered that Land Title was overdrawn a total of

$119,002.00 in three different escrow accounts, and owed First American $19,878.27 for
premiums due on title insurance written by Land Title.
5.

On February 26, 2014, the Insurance Commissioner sent a letter to Judy

Kokanos, the Designated Responsible Person for Land Title, to notify her of the
Insurance Commissioner's investigation and to request a written response to specified
queries. On March 17, 2014, the Insurance Commissioner sent a second letter. On
March 26, 2014. Ms. Kokanos sent a reply stating she was consulting with an accountant
and an attorney and needed an extension to May 1, 2014. The Insiu"ance Commissioner
granted the extension. Between March 26, 2014 and May 27, 2014, the OIC investigator
exchanged numerous emails with Ms. Kokanos. In Ms. Kokanos' communications, she
wrote she was looking for an accountant and/or an attorney. Ms. Kokanos stated that she
was scheduling a CPA to come to her office to review her accounts "to discover what
caused the issues with the trust accounts." No attorney or accountant sent the OIC
investigator a letter of representation or similar communication. The OIC investigator
notified Ms. Kokanos that, if she did not respond by June 9, 2014, the investigation
would move forward with the information that the Insurance Commissioner had. Ms.
Kokanos did not respond to the Insurance Commissioner.
6.

The OIC investigator found a copy of a February 4, 2014 Consent Order to

Cease and Desist ("C&D") filed by the State of Idaho, Department of Finance. The C&D
ordered Ms. Kokanos and Land Title to cease unlawful escrow agency operations in
Idaho on the basis of three counts: (1) Ms. Kokanos and Land Title acted as an
unlicensed escrow agency, (2) Land Title did not promptly distribute escrow funds, and

ORDER REVOKING LICENSE

ORDER NO. 14-0249
1179721

State of Washington
Office of Insurance Commissioner
5000 Capitol Blvd.
PO Box 40255
Olympia, WA 98504-0255

(3) Ms. Kokanos and Land Title did not have enough funds in its trust account to meet its
disbursement obligation to a customer, failed to deliver to the customer funds held in
escrow, and instead delivered funds to the customer from another escrow customer's
deposit. On February 4, 2014, Ms. Kokanos signed the C&D, consenting to the entr>' of
the C&D, admitting to the alleged violations, and acknowledging her understanding that
the C&D is an administrative action. Neither Ms. Kokanos nor Land Title notified the
Insurance Commissioner of the Idaho administrative action.

APPLICABLE LAW:
1.

By failing to maintain in an organized form a record of all transactions

consimimated imder its license sufficient to track each insurance contract issued, the
names of the insured or insureds, and the amount of premium paid or to be paid, the
Licensee violated RCW 48.17.470.
2.

By failing to report and account for premium fimds and to promptly pay to

the insurer or person entitled to the funds, the Licensee violated RCW 48.17.480.
3.

By failing to report to the Commissioner any administrative action taken

against it in another jurisdiction and provide the relevant documents related to such
action, the Licensee violated RCW 48.17.597.
4.

By directly or indirectly engaging in any unfair, deceptive, or fraudulent

act or practice in the conduct of its business, the Licensee violated RCW 48.29.200.
5.

RCW 48.17.530(1) allows the Insurance Commissioner to place on

probation, suspend, revoke, or refuse to issue or renew an adjuster's license, an insurance

producer's license, a title insurance agent's license, or any surplus line broker's license, or
may levy a civil penalty in accordance with RCW 48.17.560 or any combination of
actions, for any one or more of the following causes:
(b)

Violating any insurance laws, or violating any rule, subpoena, or

order of the commissioner or of another state's insurance
commissioner;

(h)

Using fraudulent, coercive, or dishonest practices, or demonstrating

incompetence, untrustworthiness, or financial irresponsibilit>' in this
state or elsewhere:

ORDER REVOKING LICENSE

ORDER NO. 14-0249
1179721

State of Washington
Office of Insurance Commissioner
5000 Capitol Blvd.
PO Box 40255
Olympia, WA 98504-0255

IT IS FURTHER ORDERED that you return your title insurance agent's license
certificate to the Insurance Commissioner on or before the effective date of the
revocation of your license, as required by RCW 48.17.530(4). Return your license to:
Licensing Manager
Office of the Insurance Commissioner
P.O. Box 40257
Olympia, WA 98504-0257
Executed this

13

dav of

Jja-c-e/vt-

,2014.

MIKE KREIDLER
Insurance Commissioner
By and through his designee

Drew Stillman
Insurance Enforcement Specialist
Leeal AITairs Division

ORDER REVOKING LICENSE

ORDER NO. 14-0249
1179721

State of Washington
Office of Insurance Commissioner
5000 Capitol Blvd.
PO Box 40255
Olympia, WA 98504-0255

NOTICE OF YOUR RIGHT TO A HEARING

If you are aggrieved by this Order Revoking License, RCW 48.04.010 permits
you to demand a hearing. You must demand a hearing in writing within 90 days after
the date of this Order Revoking License or you will waive your right to a hearing.
If the Insurance Commissioner receives your demand for a hearing before the
effective date listed on the order revoking your license, the revocation will be
automatically stayed (postponed) and your license will remain in effect pending the
hearing.
Your demand for a hearing should be sent to the following address and must
briefly state how you are harmed by this decision and why you disagree with it:
Hearings Unit
Office of the Insurance Commissioner
PO Box 40255
Olympia, WA 98504-0255
You will be notified of the time and place of your hearing. If you have
questions about filing a demand for hearing or the hearing process, please telephone the
Hearings Unit at (360) 725-7002 or send an email to HearingsU@OIC.wa.gov.

ORDER REVOKING LICENSE

ORDER NO. 14-0249
1179721

Slate of Washington
Office of Insurance Commissioner
5000 Capitol Blvd.
PO Bo.x 40255
Olympia. WA 98504-0255

CERTIFICATE OF MAILING
The undersigned certifies under the penalty of perjur>' under the laws of the state
of Washington that 1 am now and at all times herein mentioned, a citizen of the United
States, a resident of the state of Washington, over the age of eighteen years, not a party to
or interested in the above-entitled action, and competent to be a witness herein.
On the date given below I caused to be served the foregoing ORDER
REVOKING LICENSE on the following individual and Company via Email and US
Mail.
The Land Title Company of Pend Oreille County, Inc.
309 S. Washington Avenue
P.O. Box 477
Newport, Washington 99156
judy@landtitlecompany.net

Dated this 23'^'' day of December, 2014, in Tumwater, Washington.

Christine M. Tribe

ORDER REVOKING LICENSE

ORDER NO. 14-0249
1179721

State of Washington
Office of Insurance Commissioner
5000 Capitol Blvd.
PO Bo.x 40255
Olympia, WA 98504-0255