Title Service Fees when not obtaining Title Ins

We occasionally obtain a title opinion from the title company instead of getting a lender's title policy. Since the title related charges are not a component of issuing title insurance or conducting a closing, should we disclose the fees with the word Title- in front of the fees?

I always have as it's our assurance of a clear title to the collateral.

Yes, but if all you are doing is a title search, it probably belongs in Section B and labeled "Title Search". I don't think it meets the standard of "required for the issuance of title insurance policies to the creditor in connection with the consummation of the transaction or for conducting the closing."

Randy, that's what I was thinking. We have been disclosing with Title- before the fee but after reading the compliance guide again I don't feel that it's the correct way to disclose.

Iowa requires an opinion as part of their process of perfecting title and issuing title guaranty.
State law also requires an abstract update.
Both of these items are shown in B with 'Title - ' preceding them.
Especially because you're having a title company do the letter for you, I would definitely follow suit and show it in B as Title - Title Opinion.

I think the Power's that Be use way too much secondary market terminology and thinking. And always have. Title work is title work, regardless of what form it's in.

We use "Title - Title search"

Since this is an issue that actually has little importance, choose your poison and stick with it.

In Texas, a banker can make a loan without a title search or title insurance if they choose. If they choose to just get a title search, it has nothing to do with title insurance or closing the transaction, as they are most likely closing it themselves. Maybe State law has an impact, maybe not. I can only go by what the regulation states, it has to be related to the provision of title insurance or closing.