Is it ok for a Bank to lump together title/attorney fees on the CD that are itemized individually on the ALTA statement?

For example, Lenders Title Insurance and Closing Protection Letter fee are itemized on the ALTA statement, but on the CD, they are lumped together and disclosed only as Lender's Title Insurance. The Attorney fee, Cyber Security/Wire Ins fee, Filing fee, Overnight Delivery fee, Post Closing fee and Title Commitment fee separately itemized on the ALTA statement, but are lumped together and disclosed as Closing fee. (These all start with Title; I just didn't feel like typing it each time)

There are no provisions to lump together totally different services. The only title services that I have seen lumped together are separate endorsement charges to the title policy itself, but then again, it is not specifically addressed in the regulation nor did the CFPF answer any inquiries on this practice in the comment letters to the proposed TRID 2.0.

(2) Services borrower did not shop for. Under the subheading “Services Borrower Did Not Shop For” and in the applicable columns as described in paragraph (f) of this section, an itemization of the services and corresponding costs for each of the settlement services required by the creditor for which the consumer did not shop in accordance with § 1026.19(e)(1)(vi)(A) and that are provided by persons other than the creditor or mortgage broker, the name of the person ultimately receiving the payment for each such amount, and the total of all such itemized amounts that are designated borrower-paid at or before closing. Items that were disclosed pursuant to § 1026.37(f)(3) must be disclosed under this paragraph (f)(2) if the consumer was provided a written list of settlement service providers under § 1026.19(e)(1)(vi)(C) and the consumer selected a settlement service provider contained on that written list.

(3) Services borrower did shop for. Under the subheading “Services Borrower Did Shop For” and in the applicable column as described in paragraph (f) of this section, an itemization of the services and corresponding costs for each of the settlement services required by the creditor for which the consumer shopped in accordance with § 1026.19(e)(1)(vi)(A) and that are provided by persons other than the creditor or mortgage broker, the name of the person ultimately receiving the payment for each such amount, and the total of all such itemized costs that are designated borrower-paid at or before closing. Items that were disclosed pursuant to § 1026.37(f)(3) must be disclosed under this paragraph (f)(3) if the consumer was provided a written list of settlement service providers under § 1026.19(e)(1)(vi)(C) and the consumer did not select a settlement service provider contained on that written list.

It seems clear that you have to itemize out the fees, because the Regs require an "itemization of the services". Granted, the industry standard is to lump together some same/similar fees. Like Randy I always see endorsements lumped together. I've also seen multiple title search/title update/title abstracts lumped together, because these are all title searches. I have not seen anyone lump together fees to the extent you've described.