You should disclose the discounted amount of the owner’s title policy, $365, under “Other Costs” in the “Seller-Paid” column. The Closing Disclosure rules require you to disclose title insurance charges, even if paid by the seller, under “Other.”

Based on informal guidance we received from a CFPB attorney, you may disclose the owner’s policy as discounted, at $365 — assuming that you know that the simultaneous issuance discount is available and that both policies will be purchased simultaneously. However, it is important to note that if the discount instead applied to the lender’s policy, a complex calculation method from the Official Interpretations would kick in and would significantly alter how you disclosed the lender’s premium. Fortunately, the CFPB has assured us that the complex calculation method does not apply in this case, since the simultaneous issuance discount is applied only to the owner’s policy.

For resources related to our guidance, please see:

• Regulation Z, 12 CFR 1026.38(g)(4) (“Under the subheading “Other” and in the applicable column as described in paragraph (g) of this section, an itemization of each amount for charges in connection with the transaction that are in addition to the charges disclosed under paragraphs (f) and (g)(1) through (3) for services that are required or obtained in the real estate closing by the consumer, the seller, or other party, the name of the person ultimately receiving the payment, and the total of all such itemized amounts that are designated borrower-paid at or before closing.”)