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#2251925 - 04/07/21 01:48 PM New Software - Disclosing Title Insurance
ComplyCycle Offline
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ComplyCycle
Joined: Dec 2014
Posts: 454
Hi, I know this topic has been discussed repeatedly but we are testing out a new fee generation software and I have some questions on the functionality. We are in a simultaneous discount state in which the seller pays for the owner's title insurance.

We had been disclosing a seller credit in the "Calculating Cash to Close" table so the LE reflected actual costs to the parties. The new software lists both lender's and owner's title as buyer paid without a corresponding seller offset on the LE. However, if we mark the owner's title as seller paid within our LOS then the "Estimated Cash to Close" on the LE is reduced by the owner's title. My confusion stems from the fact that besides marking the owner's title as seller paid within the LOS, I am unable to see any location on the LE that reflects that.

Basically, my question is if it's ok for the "Estimated Cash to Close" to omit owner's title costs (so "Estimated Cash to Close" provides actual buyer costs) and for owner's title to not be listed elsewhere on the LE as seller paid?

I hope this makes sense, but let me know if I can clarify anything. Thank you.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2251928 - 04/07/21 02:02 PM Re: New Software - Disclosing Title Insurance ComplyCycle
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I am having a hard time visioning how that is going to work. You have to disclose the undiscounted lender's title policy and I am not sure how you can do that without a seller's credit being reflected whether or not you show the owner's title policy charges in Section H. You can omit the owner's title policy charge from Section H, but you still need to account for the remaining seller's credit otherwise your LE will not be in good faith.
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#2251934 - 04/07/21 02:33 PM Re: New Software - Disclosing Title Insurance ComplyCycle
ComplyCycle Offline
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ComplyCycle
Joined: Dec 2014
Posts: 454
Thank you. That was my concern as well. I'll reach out to our vendor for additional information.

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