- Business Rules
With the requirement to show full amount of Lender's Title Insurance and full amount of Owner's Title Insurance Amount, has CFPB addressed that this would never be the case and grossly misrepresents the cost of getting both thus scaring the consumer from obtaining owner's insurance which would protect them?This scenario only applies in those states which have allowances for reduced lender policy premiums when a simultaneous owner’s policy is also issued. The CFPB and Title Insurance providers associations are aware of this conflict and the title association (ALTA) has prepared documentation for use by title insurers for this purpose. It would be recommended you work with your legal counsel or compliance experts to determine if and how you may want to identify this issue to the consumer.
Citation(s): Commentary ¶19(e)(3); State Law; American Land Title Association
CFPB announcement regarding the delay of TRID
The full statement from CFPB Director Richard Cordray can be viewed here