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What is the correct way to disclose a seller-paid owner’s title insurance policy on the Closing Disclosure? – IBA Compliance Connection

IBA Compliance Connection

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What is the correct way to disclose a seller-paid owner’s title insurance policy on the Closing Disclosure?

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

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.”)