December 15, 2009
An unpublished court of appeal decision refused to extend escrow responsibility to a non-party warehouse lender who provided no escrow instructions. The court also followed a recent decision that forged notes did not create any indebtedness under title policies because no money had been actually loaned to the purported borrowers. The court did not address whether the title policies were void because of the fraud of the insured or the issue of rescission of a title policy.