The Consumer Financial Protection Bureau’s (CFPB’s) TILA-RESPA Integrated Disclosure (TRID) Rule is quite specific regarding fees and forms, while in other areas it is a bit vague.
For example, endorsement charges are not addressed. The disclosure of the policy premium is discussed but there is no specific guidance as to how to disclose endorsements.
CFPB’s TRID Rule was enacted to help consumers better understand their obligations in a real estate transaction along with the fees and premiums incurred. In that spirit, it is best to disclose any endorsement fees separately on the disclosure forms. When listing endorsement fees on the new forms, the Loan Estimate (LE) or the Closing Disclosure (CD), the listing must begin with the word “Title – “ followed by the description of the endorsement. The placement of the fees will be in Sections B or C (LE and CD) if the endorsement appends the Loan Title Insurance Policy and in Section H (LE or CD) if the endorsement appends the Owner’s Title Insurance Policy.
Listing the endorsement fees separately from premium disclosures will better ensure that the consumer fully understands the closing transaction.
Call your Old Republic Title agent or office to discuss the endorsements available for your transaction.