In some cases, if a customer chooses a certain attorney for title work, the bank retains a portion of the title insurance fee. We do not have an affliate relationship though. Under the current rules, we disclose the entire title insurance amount and then on the HUD, the bank portion and underwriter portion are itemized. Thoughts on how this should be disclosed under TRID?

The Bank retains a portion of the fee???It actually sounds like a kickback to me. What does the Bank do to earn this fee for the issuance of title insurance????

You must be in a very unique State that would even allow for this.

You treat this fee as a pre-paid finance charge - correct, as I can't imagine what you are doing to earn it?

Under TRID, it would be a Section A charge on the LE.

We've had this in place for years and so far, no issues with examiners and they are aware of it and it's been disclosed separately on the HUD. I know of other banks that have done this in past. Anyone else currently doing it that is willing to share your plans under TRID?

What do you mean by plans under TRID? It is a payment to the creditor - it has to be treated as such. I guess I do not understand the question.