Should Transfer taxes on the CloD always have the title 'Transfer Taxes' or can it deviate for example be listed as 'State Registration Tax'? In §1026.38(g)(1) it states "An itemization of transfer taxes, with the name of the government entity assessing the transfer tax." My interpretation is to disclose the specific name of the fee as in example #2 provided below. However, a LO is stating their interpretation is the fee always has to be called the Transfer Tax and then the Bank can itemize for the different Gov't entities assessing the tax as in example #1 below.

1)Transfer Taxes to County Treasurer

Or

2)State Registration Tax to County Treasurer

I'd appreciate any guidance. Thanks!

(ii) On the second line, the sum of all transfer taxes paid by the consumer, labeled “Transfer Taxes.”

See Model H-25(B).

(ii) On the second line, the sum of all transfer taxes paid by the consumer, labeled “Transfer Taxes.”

Thank you. I also found the above statement in 1026.37(g)(1)(ii) for the Loan Estimate but couldn't find that verbiage in 1026.38 (g)(1) in regards to the CloD. The Model form for the CloD you referenced above does have it labeled as Transfer Taxes though so I'll proceed in that direction. I feel 1026.38 is vague on how itemized taxes should be labeled. Thanks!

ns, on my LE it simply says 'transfer taxes' for all transfer tax categories, lumped together.

On my CD it separates out like this [for my state]

State Tax Stamps - Deed
State Tax Stamps - Mortgage

And lists each individual tax and who pays it.