An Express Article from the California Land Title Association
Bulletin 13/14-5 - August 1, 2013
The Department of Justice (DOJ) has made minor technical amendments to its proposed Electronic Recording Delivery System (ERDS) regulations, specifically: Article 4. Fingerprinting and Criminal Record Checks, and Article 7. Computer Security Auditor. The proposed amendments have been submitted to the Office of Administrative Law (OAL) and are open for public comment. The notice for the proposed amendments is available on the Attorney General website here; text of the proposed regulations is available here for Article 4, and here for Article 7.
The CLTA e-Recording Task Force, chaired by Paul Flores, has reviewed the changes and found no need for substantive comment. Specifically, the changes are as follows:
The first change is due to the enactment of AB 2343 on January 1, 2013. The bill allows specified applicant agencies to receive subsequent disposition information in addition to the subsequent arrest information that the ERDS program already receives pursuant to a criminal history background check. This change affects the following sections within Article 4, 999.121 (e) and (f) and sections 999.191(2) within Article 7.
Second, the ERDS program will leave the Auditor years of experience at 2 years and not reduce it to 1 year. The reason for this is that the ERDS program wants to draw in the best possible candidates. This change affects the following sections within Article 7, 999.190 (2)(A),(2) (B),(2) (C),(2) (D),(2) (E), and 999.195 (b), (c), (d), (e), and (f).
Any written comments should be submitted directly to representatives from the DOJ by close of business on Thursday, August 15th. Contact information is included below.
Michelle N. Mitchell, Field Representative
California Department of Justice
California Justice Information Services Division
Electronic Recording Delivery System
P.O. Box 160526
Sacramento, CA 95816-0526
Telephone: (916) 227-1127