disclosing owner's title 50/50 split

Does anyone have any guidance for disclosing the CD when the owner's title cost is split 50/50 between buyer and seller? We have several title insurance calculators that help us figure out how to disclose and what credits to give when it is 100% seller paid, however they do not work when the owner's title is split 50/50.

Don't you just put 50% in the "Paid by Borrower" column and 50% in the "Paid by Seller" column??

Or I don't understand your question.

Or are you in a simultaneous issue discount State?

We are in a simultaneous discount state.

OK - Give us some actual figures to work with..

Disclosed LTP
Actual LTP
Disclosed OTP
Actual OTP

I would better with numbers.
.

We are in a simultaneous discount state as well, but the 50/50 split twist is new, however I think I can still help.

Example: Owner's Title = $800, Lender's Title = $600, Simultaneous Issue Fee = $50
The end math needs to work out so Borrower pays $450 and Seller pays $400.

Under Section B or C (depending on whether the Borrower shopped) you enter the full Lender's Title at $600.
Under Section H (Other) you enter the Owner's Title at $250 [800+50-600 per 1026.37(g)(4) Commentary] in the applicable Seller-Paid column.
In Section L under Seller Credit enter $150 [400-250]
With this Seller Credit the Borrower ends up paying $450 [600-150] for Title Fees.

It's not pretty but I think it is compliant.

Good Luck!

Confused regarding simultaneous issue.

Using Kat's example above for the Closing Disclosure, why would you not show the Lender's Title Insurance as $50 & the Owner's Title Insurance as $800? I thought the Closing Disclosure was suppose to show the "actual costs" of the transaction.

Commentary from 1026.37

2. Simultaneous title insurance premium rate in purchase transactions. The premium for an owner’s title insurance policy for which a special rate may be available based on the simultaneous issuance of a lender’s and an owner’s policy is calculated and disclosed pursuant to § 1026.37(g)(4) as follows:

i. The title insurance premium for a lender’s title policy is based on the full premium rate, consistent with § 1026.37(f)(2) or (f)(3).

ii. The owner’s title insurance premium is calculated by taking the full owner’s title insurance premium, adding the simultaneous issuance premium for the lender’s coverage, and then deducting the full premium for lender’s coverage.

Kat's got it correct.