Special Alert: NL000073

Dear Associates:

Over the past several years, many states have passed legislation and/or regulations requiring insurance companies to implement Anti-Fraud Plans. This Bulletin is to provide you with some basic information regarding the Anti-Fraud Plan that has been established by Stewart Title Guaranty Company.

Stewart Title Guaranty Company ("Stewart") has an Anti-Fraud Plan which was implemented in 1993, and at that time an in-house Special Investigative Unit ("SIU") was created. The total number of associates on the SIU investigative staff is 93. The SIU includes all employees who may potentially be involved in an investigation, although these associates have many other duties and responsibilities. The SIU consists of the General Counsel, the Chief Claims Counsel, Seven National Claims Counsels and their assistants, five claims administration support staff, and 53 Field Customer Service Representatives ("FCSRs") located in various states across the country.

There is also an Anti-Fraud team, which has a core group of nine people: the Chief Claims Counsel, Seven National Claims Counsels, and the Assistant Vice President of Claims Administration. In addition to the core group, the expanded Anti-Fraud team includes one Senior Underwriting Counsel, the Senior Vice President of Audit Services, and a representative from National Accounting. The Anti-Fraud Team Core Group meets regularly to discuss process improvement, and to ensure compliance with state requirements regarding anti-fraud legislation.
The general plan includes eight sections:

1.) the Special Investigative Unit and the Anti-Fraud Team;
2.) Employee/Agent Fraud;
3.) Claim Fraud;
4.) Education;
5.) Security of Company Data Processing;
6.) Contracting of Fraud Investigators;
7.) Notice to Authorities; and,
8.) Company Contact Person.

If you become aware of any activity which you feel may constitute an effort to defraud Stewart, please report the activity to John L. Killea, General Claims and Chief Compliance Officer Counsel.