Are title companies subject to Reg E remittance rules and would the bank have to provide vendor management oversight for the title company's activities--especially if the title company is using a software where the title company can initiate the wire itself without help from the bank?
(f) Remittance transfer provider. (1) General definition. "Remittance transfer provider" or "provider" means any person that provides remittance transfers for a consumer in the normal course of its business, regardless of whether the consumer holds an account with such person.

You'll have to describe the nature of the transfers. My understanding of the role of title companies with regard to remittance transfers is that they would not be initiating them on behalf of consumers/senders for personal, family or household purposes.

But I'm open to expanding my understanding if you are asking about transfers that you think might be covered.