Owners vs Lenders Title Insurance GFE

We sell some loans to the secondary market. On purchases, we disclose an owners title insurance, which includes the $75 for lenders title insurance. After reading the Q&As I believe we would need to show both a lenders and an owners title insurance. After discussing this with the department, they told me that the lenders title insurance is part of the committment fee, which is included in our origination.

This makes it very difficult to break out the two values. Any thoughts?

Lenders Title Insurance should be included in the lump sum total of block 4 of the GFE/Line 1101 of the HUD1. The OTI is a seperate line item on each form.

I do not disagree, however that was not the question (although I did just put any thoughts ). The problem is that we are not charged a fee specifically for owners TI. We are charged a committment fee. The committment fee is used by the investor to pay OTI. Thus, are we ok just including the commitment fee, as part of the origination fee?

I apologize I mean lenders title insurance.