The statute names no file. Here is the one we keep.

Does SB 17 require a title agent to keep a file?

No. Nothing in Subchapter H names a file, a form, or a retention period for anyone who assists with a transaction. Everything below is a practice rather than a requirement, and your office and your counsel decide whether to adopt any of it.

What goes on each file?

Eight items, in the order the work happens. This is the shape of a ParcelClear record, and an office that keeps none of it has broken no rule.

1. 1The questionnaire answers, as the party attested them, and the date of the attestation.
2. 2Every party and every control person, with role and party type.
3. 3The control-person tree for an entity or trust buyer, with the reviewer's statement that it is complete from the documents in the file.
4. 4The OFAC SDN and Consolidated screen of every name, with the list version and the date that list was fetched from Treasury.
5. 5The disposition of every potential match, with a written reason and the reviewer who recorded it.
6. 6The rule set id and version that evaluated the answers, and the id of every rule that fired.
7. 7The result, NO RULE TRIGGERED or HOLD or REPORT, and what the office did next.
8. 8The SHA-256 of the finished pack, and the address a recipient uses to check it.

Why record the list version and the date?

A sanctions list is a snapshot. A screen is evidence of what the list said on the day you asked, and nothing more than that. Without the version and the fetch date, a screen result is an assertion with no way to check it. ParcelClear holds instead of returning a result when the newest successful ingest is more than seven days old.

What does a disposition need to say?

Who looked, what they looked at, what they concluded, and when. Most potential matches are false positives: common names, transliterations, partial overlaps. A disposition with a written reason is what turns a hit into a decision a stranger can read eighteen months later.

Why hash the file?

So a later reader can tell whether the PDF in their hands is the one that was generated. The pack prints its own SHA-256 and the address that checks it. Recompute the hash, compare the two, and the question of whether the document changed is settled without taking anyone's word for it.

Is this checklist a standard?

No. Neither the statute nor the proposed Chapter 67 rules define a standard of diligence or a record to keep, so nobody is in a position to hand you one. This is what ParcelClear records, written down so an office has something concrete to accept, change, or reject with its counsel.