On the Written List of Providers we disclose the Title Insurance Company's name for all the services that will be executed/obtained through a Title Company. This includes Lenders and Owner's Title Insurance policies.

When it comes to the CD, if these insurance polices are purchased, we will put the name of the Title Company after that fee - Title - Lender's Title Insurance to ABC Title Co.

I'm reviewing a TRID loan and for the first time I am seeing that the name of the the actual company that the title insurance policy is being written through was named.

I know the rule says the "person ultimately receiving the payment for each such amount", but I seem to remember that we don't actually have to drill down to the down to the third parties that the Title Company is using.

Is it ok to disclose just the Title Company's name or should we be disclosing the names of the third parties they are using, such as for title insurance, couriers, etc.?

I am not sure there really is any guidance. But if you go down that road, as you noted, it becomes a very slippery slope and most title companies are going to be less than cooperative.