Title agent accused of rebranding to evade fraud penalty

First American Title Insurance Co. is suing a former agent to recover sums owed after her firm erroneously wired funds, claiming she changed her business' name to evade more than $600,000 in penalties.

In a lawsuit filed in Eastern District Court of New York, First American accused Patricia Stein-Oliva, principal of Consumer Direct Title Agency, of rebranding to its current name in an effort to avoid likely future financial obligations, just as judges were determining an appropriate penalty after ruling against her in an earlier civil suit.  

Stein-Oliva formerly owned and headed Long Island, New York-based Liberty National Title Agency, which entered into an agreement to become a policy issuer for First American in 2012. In the current lawsuit, Liberty, two Consumer Direct entities in New York and Florida and Stein-Oliva are all listed as defendants. 

"This action seeks to unwind that fraudulent scheme and to hold each defendant – each a mere alter ego of Liberty – jointly responsible," First American attorneys wrote, referring to the lawsuit. 

"Defendants have abused the corporate form to insulate Liberty and its principal from satisfying the judgment they indisputably owe."

The sequence of events

In a June 2020 New York residential transaction where Liberty was assigned as closing and settlement agent, the firm received a faxed statement indicating a mortgage held by the Department of Housing and Urban Development had been paid off. Instructions directed Liberty to wire payoff funds to a Comerica Bank account belonging to FF Operations. 

Despite public HUD and servicer policies stating wire funds were not acceptable for payoffs, Liberty sent more than $371,000 held in client escrow to what turned out to be a fraudulent account, failing to confirm the validity of the instructions with any of the transaction's other associated parties, attorneys wrote. Non-verification constituted a violation of Liberty's agreement and underwriting requirements with First American.

The Southern California-based title company was eventually forced to cover the full amount fraudulently wired to comply with terms of its insurance policy after Stein-Oliva refused to pay from her own business funds, despite terms of their contract.

A civil suit lodged by the title company two years later eventually led to a court decision in 2024 in favor of First American. The judge's ruling found Stein-Oliva's company liable for $611,070, a total that included compensatory damages and related legal fees. 

Upon collection attempt, Stein-Oliva declared under oath that Liberty ceased operations in December 2024 and no longer owned any assets.

"Investigation into Liberty's activities revealed that it had in fact not ceased operations, as Stein‑Oliva had falsely affirmed, and had instead simply changed its name to avoid satisfaction of the judgment," First American's lawyers stated in the legal filing.

Further investigation uncovered that in August 2024 — while determination of the amount  of monetary damages owed was underway — Stein-Oliva had formed Consumer Direct Title Agency in New York. Findings also showed Liberty continued operating under its own name as a foreign corporation in Florida. 

In January 2025, immediately after financial damages were awarded, Liberty withdrew from Florida, replaced by a newly incorporated Consumer Direct Title Agency, with Stein-Oliva listed as president. Headquarters of the new title firm corresponded to its New York counterpart, with the address of both at the same Melville, New York location previously belonging to Liberty. 

"Stein‑Oliva — the sole principal of both Liberty and the Consumer Direct entities — exercised exclusive dominion and control over each entity, orchestrated the restructuring and rebranding of the business, and deployed the Consumer Direct entities as a mere continuation and alter ego of Liberty to evade satisfaction of the judgment," the lawsuit claimed. 

With those findings, First American was able to garnish over $90,000 of the amount owed still held in a Liberty bank account. 

The lawsuit also pointed to Stein-Oliva's public acknowledgements that Consumer Direct was "formerly Liberty National Title" on various social media channels and in marketing materials, where she referred to the new name as a "rebrand."

With the marketing claiming a direct link to Liberty and continuity of leadership, First American characterized that the rebrand to Consumer Direct entities effectively qualified as a "de facto" merger, which would make them responsible for assuming Liberty's legal obligations

"This sequencing and continuity were undertaken for the purpose of hindering, delaying or avoiding enforcement of Liberty's judgment obligations while continuing the same title insurance business under a different name and corporate form," attorneys alleged.

Consumer Direct did not respond to an emailed request for comment regarding the allegations. A representative from First American said the company could not publicly comment on active litigation.  

Along with the remaining compensation owed in connection with the 2020 fraudulent wire and initial penalty judgement, First American is requesting courts to impose a constructive trust or lien over assets belonging to Consumer Direct and order an accounting of all its assets, revenues and business activity. It is also asking for "further legal, equitable, and declaratory relief as the court deems just and proper" and imposition of measures to prevent Stein-Oliva from transferring or concealing existing assets of her business.