Any specific service has to be separately disclosed. The CFPB was asked to clarify this during the comment period to TRID 2.0, but declined to do so. So, it comes down to how far do you really have to drill down.
Do you disclose the title company's attorney, if you are paying the title company and they are paying them? What about their courier fee - do you disclose that you are paying the title company or are you listing Fed Ex or Joe Courier? How far down the rabbit hole do you have to go?
I think the logical thing is to stop at the first payee. If you have XZY Title company on your SPL and you know that XZY Title will choose an attorney, I do not think that you have to then list every attorney they might select. You would list Title - Attorney Fee and the title company as the provider.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com