No, we are not aware of any Illinois law that addresses how you should disclose title insurance charges. When disclosing title insurance charges in Illinois, your institution should follow the TRID rules.

For more information on the TRID requirements for title insurance disclosures, we recommend reading the following IBA Q&As:

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

• In the new Closing Disclosure, where should we disclose a seller’s payment for the owner’s title insurance policy? What if the title insurer discounts the owner’s policy when it is purchased at the same time as the lender’s policy? For example, the lender’s title policy is $300, the owner’s title policy is $400, and a $35 discount is applied to the owner’s title policy, making it $365.

• In Illinois, the seller usually pays for the owner’s title policy. Should we disclose the owner’s policy premium on the Loan Estimate?