The CFPB provided guidance to the industry on the negative amount for owner’s title insurance policy question during their webinar on April 12, 2016. Below is the question and response from the CFPB during the webinar.
Q7: The calculation of the owner’s title policy premium in accordance with the rule might result in a negative number. Does the creditor disclose this negative number for the owner’s title policy on the Loan Estimate and Closing Disclosure?
Dania Ayoubi, counsel in the CFPB’s Office of Regulations, said that in this situation, the creditor would disclose the premium for the owner’s policy as a negative number. “When a simultaneous issue rate or discount is used—mostly in purchase transactions—the cost of an owner’s title insurance policy is disclosed as the incremental cost of that owner’s title insurance beyond the standard non-discounted cost of the lender’s title insurance policy,” Ayoubi said. “When disclosed in this fashion, the disclosure conveys to the consumer that it is less expensive to purchase both owner’s title insurance and lenders title insurance together than it is to purchase just lenders policy by itself.”
She referenced Comment 37(g)(4)-2 of the rule, which states “The premium for an owner’s title insurance policy for which a special rate may be available based on the simultaneous issuance of a lender’s and an owner’s policy is calculated and disclosed pursuant to § 1026.37(g)(4) as follows: The title insurance premium for a lender’s title policy is based on the full premium rate, consistent with § 1026.37(f)(2) or (f)(3). The owner’s title insurance premium is calculated by taking the full owner’s title insurance premium, adding the simultaneous issuance premium for the lender’s coverage, and then deducting the full premium for lender’s coverage.” Ayoubi stated that there are no provisions in Regulation Z that would prohibit the cost of owner’s title insurance from being disclosed as a negative number.
Posted in CFPB, CFPB Webinar, Owner's Title Insurance, TRID
Tagged CFPB, CFPB Webinar, Closing Disclosure Form, Consumer Financial Protection Bureau, Implementation, Owner's Title Insurance, SoftPro, TRID
JPMorgan Chase is selling their rural housing business to Freedom Mortgage in an attempt to simplify their mortgage business.
Full article can be found at JPMorgan sells USDA business to Freedom Mortgage
Guaranty Fee Goes Into Effect April 1
The Texas Title Insurance Guaranty Association board voted to reinstate the Policy Guaranty Fee at $3 per policy for all transactions closed on or after April 1, 2016.
According to the TTIGA Guaranty Fee Frequently Asked Questions, “The charging of the Guaranty Fee is determined by the closing date, or more specifically, the date the closing documents are signed. For example, if a transaction has closing documents signed in March, but the transaction does not fund until April, then no fee should be collected. If the closing documents are signed April 1 or later, the fee to be collected is $3.00…The guaranty fee should be disclosed on the Closing Disclosure and, if not separately itemized on the closing disclosure, the policy guaranty fee should be shown on the Texas Disclosure (Form T-64) in the Other Disclosures section.” In addition, “Guaranty Fees are reported on the Guaranty Fee Remittance Form (TDI’s Form No. T-G1) on a quarterly basis with one form and one check submitted to TTIGA.”
The remittance form is available in two formats (PDF fillable and printable for writing by hand) on the TTIGA website. The Guaranty Fee FAQs appear on the Guaranty Fees page of the TTIGA website.
Notification: RealEC Closing Insight Registration Issue
Issue: Delayed order processing with Incorrect Party ID Assignment AND ‘new’ invitation(s) being sent
Cause: Selection of “Incorrect” firm via drop-down list
Workaround: Do NOT accept new invitations from RealEC / Lenders IF you have previously registered. Contact lender and advise to
1. Cancel the order 2. Resend the order to your existing party ID
Details: Many customers are receiving emails from lenders and/or RealEC requesting registration. Lenders are accidentally bypassing the ‘provider selection’ drop-down list and firms are receiving a ‘new’ invitation when they are already registered. If you have already registered, do not accept a new registration. These new registrations will have not have a party ID configured for your firm and it will delay order processing.
Follow-up: If you have any questions or need clarification, please contact your SoftPro Administrator or the SoftPro Help Desk.
Congratulations to Priority Title & Escrow, a SoftPro Select customer, on successfully closing the FIRST post-TRID loan! Mike Steier, Vice President of Priority Title & Escrow said, “The SoftPro upgrade process, training materials, support, and the SoftPro software itself made the new transaction EASY! Everything was fantastic and smooth, we had no issues, thanks to SoftPro!” This is an extremely exciting accomplishment, and we are so glad SoftPro was able to aid Priority Title & Escrow in the success of the transaction!
To learn more about SoftPro’s award-winning software and support, visit www.softprocorp.com