1. CFPB Overview Simultaneous issue John Martin August 17-21

2. The Problem - When both a loan and owner’s title insurance policies will be purchased in a transaction (called “simultaneous issuance”) the TRID requires the lender or settlement agent to inaccurately disclose the title premiums on the Closing Disclosure.

3. How does the Rule handle:
Regardless of lower, actual simultaneous issue rate for Lender’s Policy, pricing to be shown at full rate.
If an Owner’s Policy is also purchased, rate shown is in accordance with CFPB formula – again, not the actual rate charged

4. LOAN POLICY
Under TRID, the loan policy must be shown on the Loan Estimate and Closing Disclosure at the full rate without adjustment for simultaneous issue, regardless of whether the filed or promulgated rate for a simultaneously issued loan policy is lower

5. Owner’s policy
Under TRID, the Owner’s policy must be shown on the Loan Estimate and Closing Disclosure according to the CFPB formula:
Owner full Loan policy Full Loan
Premium Simultaneous Premium
Premium

6. Owner’s Standard premium -- $1,782 Lender’s premium (full) -- $1,630
Example
Sales Transaction
Sales price -- $500,000, Seller pays Owners
Loan Policy -- $400,000, Buyer pays Lenders
Extended
Owner’s Standard premium -- $1,782
Lender’s premium (full) -- $1,630
Lender’s premium (Simultaneous) -- $610

7. Closing Disclosure under TRID rules
Owners (full owner + Loan Sim – Loan Full) $1, ,630 = $762 Loan (full rate) -- $1,630

8. Comparison between TRID and actual
TRID Actual Owner’s -- $ 762 $1,782 Loan -- $1,630 $ 610 Total $2,392 $2,392

11. Useful Resources CFPB website: http://www.consumerfinance.gov/
Small Entity Compliance Guide:
Disclosure Timeline Example:

12. Useful Resources
Form Guide:
Stewart CFPB blog:
ALTA website: (search “CFPB”)