I'd like to resurrect this old thread since we're revisiting our process for disclosing owner's title insurance.
In our state, it's customary for the seller to pay this fee (since this is how our purchase contracts are written). Because the seller pays for owner's title and it's not a cost the borrower has to pay, I am hoping we can omit this fee from the initial LE. Based upon the rule, preamble cited above, and spirit of TRID to only disclose accurate applicant costs (not likely to be help me in a disagreement with examiners, I know), I believe we are fine to omit this fee.
My challenge is that I've received conflicting responses from the ABA and my state banking association, so I'd like a third-opinion to break the tie, please.
Do you think we'd land in any regulatory hot water for not disclosing owner's title on the initial LE? Thank you.