Instructions for the 1100 Series states that charges to third parties must be broken out in the appropriate lines or blank lines in the series. (I always read this as a third party to the title company.)

I know we identify the closer on line 1102 and who received the title insurance premium on line 1104. (those are generally the same for us)

What if we close in-house and do not purchase title insurance but we do pay for a title search? The fee for the search is included in the lump sum on line 1101. Does the search have to be separately itemized identifying the provider? If so what line - 1109 or higher?

Thank you. I get more confused every day.

A third party, as defined by Ms. Vicki Bott in the HUD-RESPA webinar in March, is someone the title company would hire to do something for them. You are the first party and the title company doing the search for you is the second party.

So to me that means that if the title search is the only charge in the 1100 Series, I don't need to identify the title company. Do you agree?

I really need to know what people think on this. How do others handle it?

I think that depends. If they are preparing the HUD and their name/address/phone is listed on page 1, then it's redundant and unncessary, but if you are handling the closing and they are not listed anywhere else, I would think they should be listed.