Question:
Block 4 requires the lender to disclose the lender’s portion of the title insurance plus any other title services fee charged to the borrower. Block 5 requires the lender to quote the owner’s title insurance premium. These are not itemized for the GFE purposes; however, some of the fees need to be broken out for TIL purposes in order to get them to calculate in the APR. One title company we deal with indicated to us that owner’s title insurance premium equals the total premium (required for both owner’s and lender’s) minus the premium (on their rate sheets) for the lender’s portion of the premium. Another states that the owner’s portion is the entire premium and that they issue a simultaneous lender’s policy for $25.00. Based on from whom we get our quote, we will be disclosing differently on certain files; however, the ultimate “total cost” is the same. Is this okay?
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