Depending on who you talk to some believe that on a purchase, even if the seller is paying the owners policy, that it must be disclosed as a buyers cost.  On the new GFE box 4 is for the lenders title policy and box 5 is for the owners title policy.  If you don't disclose the cost of the title policy then at closing there is a comparison between the inital GFE and the final acutal costs.  The new law only allows for a 10% variance if they use the provider that you quoted.  If you showed 0 and the actual cost is $1,000 then it looks to me like you are responsible for $1,000.  However, read the 48 page Q&A sheet put out by HUD, just updated last week to include reverse mortgages.

Bryan,

Thank you for your reply. We are a small credit union, and we have an attorney who does our title searches for us and guarantees the searches. We do not require title insurance at all. Do we have to put anything in those blocks?

I have read the FAQ booklet, I have a highlighted copy sitting here right now! I'm just trying to get ready for the changes.

Thanks again.

If you are doing a purchase does the seller pay for the Owners Policy or is there none with the work that your attorney does?  If any is ever paid by anyone when they do loans through you. even when paid by the seller, according to our compliance department, it must be disclosed.  However, I have had discussions with a local attorney who represents the local Realtor Association and he says that HUD is very clear that we don't need to disclose the Owner's policy since it is paid for by the sellers in our area.  Two different opinions from knowledgeable people.  HUD seems to believe that they are very clear on everything and we all have had enough time to figure it out.  What do you think?

53's interpretation (which makes sense) is that title charges and those which fall under the "Fees You Can Shop For" are not controlled by the RESPA tolerances on the GFE....

HUD has issued a 48 page FAQ guide to the new 3 page GFE and TIL.  HUD says on page 23  that on purchase transactions originators must disclose the cost of the Owners policy even if paid by the seller.  The original post comes from an area where an attorney does the work and guarantees title and evidently there is no charge for title work. 

GFE – Block 5

1) Q: Do loan originators have to provide a price for Owner‘s title insurance on the GFE?

A: