Clearing up Concerns

Tina Marie Beaver

In preparation of TRID, RBJ had provided training for its clients including teaching the simultaneously policy calculation in accordance with the TRID rule.  There may be times when the calculations result in a negative debit of the Owner’s Title Premium. In other words, a credit, such as in the case of a Binder policy, and that is how we’ve been teaching this scenario. Some in the industry have been concerned that showing a negative amount as a charge for the Owner’s Policy Premium might be against the CFPB regulation.

American Land Title Association (ALTA) has posted a blog that includes an audio recording of a webinar by CFPB that was held on April 12, 2016 clearing up this concern.  It is permissible to show a negative amount if the calculations require.  Dania Ayoubi, counsel in the CFPB’s Office of Regulations further offered 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…”

To read the entire blog and to listen to the short recording, please click here.