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#2110519 - 12/12/16 09:35 PM Title Insurance - Undiscounted Lender's
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
We are still struggling with title companies who refuse to give us quotes using the undiscounted lender's title insurance for purchase transations. Normally, I would say to not use those title companies, but we have several market areas that have limited options. Are others having the same difficulty? What do you do when the title co. won't give you the figures you need?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2110526 - 12/12/16 09:47 PM Re: Title Insurance - Undiscounted Lender's TMatt87
John Burnett Offline
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John Burnett
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Cape Cod
I'm sure you have done this already, but start by citing the regulatory requirement. For the loan estimate, it's found in comment 37(f)(2)-4. For the closing disclosure, it's in 38(g)(4)-2.

One tactic I have seen suggested in these forums is enlisting the clout of the state insurance commission.
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#2110528 - 12/12/16 10:09 PM Re: Title Insurance - Undiscounted Lender's TMatt87
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
Doesn't the State set the rates? Here is a title insurance fee chart for Idaho.

http://www.firstam.com/assets/title/id/forms/idaho-schedule-of-title-fees.pdf
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#2110530 - 12/12/16 10:53 PM Re: Title Insurance - Undiscounted Lender's TMatt87
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
We generally get custom quotes from the title companies because they each charge their own "nickel and dime" fees. On these quotes is where we have issues with them just listing the discounted LTI. Our loan officer's don't grasp the concept of disclosing the undiscounted LTI very well, so having them hand calculate the disclosed amounts for LTI and OTI would be difficult.
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#2110531 - 12/12/16 11:20 PM Re: Title Insurance - Undiscounted Lender's TMatt87
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
That is why many banks have centralized the disclosure process. I guess I am confused as to the difficulty. There are several Idaho title companies that even provide TRID calculators on-line. Since the actual insurance costs would be the same, why don't you use one of those? Here is one of the generics:

http://www.anytimeestimate.com/TITLE_INSURANCE/id-title-insurance.htm
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#2131160 - 05/19/17 04:18 PM Re: Title Insurance - Undiscounted Lender's TMatt87
Lakeminded Offline
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Joined: Mar 2014
Posts: 76
Washington
In Washington and Idaho we've come upon new challenges. the title companies all changed their rates this January and no longer offer or quote the full rate or discounted rate. The state regulated approved rates consist of a lender's policy and a general policy. Their position is that they do not fall under the CFPB. I've spoken with two other banks and one credit union in our markets and they have taken the path of least resistance - "you can't quote what doesn't exist and this is the pricing". If the position is that the approved rates don't reflect a discount (then why the two rates). I'm trying to find a logical way through this, but I wonder if other markets are seeing this?
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#2131186 - 05/19/17 06:08 PM Re: Title Insurance - Undiscounted Lender's TMatt87
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
There is nothing in the Bureau's rules that requires title insurance companies to offer simultaneous-issuance discounts on the LTI premium. The Bureau's rule is only about the proper way to disclose the LTI and OTI premiums where there IS a simultaneous-issuance discount.
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BankersOnline.com
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