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Title Insurance Enforcement Fund Fee or TIEFF

Question: 
In 1026.37(f)(5) we know that creditors are required to use terminology that is reasonably understood by consumers. We lend in Indiana in which the Title Company will charge a $5 TIEFF fee. This is an acronym for Title Insurance Enforcement Fund Fee, but it is recognized as TIEFF in the industry and is searchable on the web as TIEFF. We have an investor who is requiring the full name be placed on the CD for all IN loans versus the TIEFF acronym. We feel that the acronym is reasonably understood. The problem with using the full fee name is that it would always require an addendum due to the character limitations on the CD. Has anyone else run up against this scenario and have overcome the investors' concerns?
Answer: 

by Randy Carey: Various banks have to do a lot of things that investors require that do not make a lot of sense. Unfortunately, the investor holds the gold in this case. Continue to work with them and continue to suggest they change their ways or find a new investor. Those really are your only options.

Answer: 

by Dan Persfull: To the best of my knowledge the following bulletin has not been rescinded for how to disclose the TIEFF on the Closing Disclosure under IN statutes.

http://www.in.gov/idoi/files/Bulletin139.pdf

For residential transactions, the five dollar ($5) fee must be reflected on the HUD 1 or the Settlement Statement as the TIEFF.

The TIEFF fee is under IC 27-7-3.6-7.

First published on 05/21/2017

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