Information Center

Is there going to be a special “worksheet” to calculate the credit to the Buyer for the title fees in a contract where the seller pays for the owners’ policy?

In DoubleTime the rating calculator will produce a worksheet which reflects Florida rates. The Florida charges will automatically convert to TRID rates for display in the Closing Costs tables on the CD. DoubleTime will also populate a Florida Insurance Premium Disclosure you can use to compare Florida rating to TRID rating.

With that document you can subtract the Florida rate for the loan policy (which includes any endorsements) from the TRID rate for the same and the difference will be the adjustment amount for which the seller is responsible.


If there are miscellaneous affidavits needed to clear the title, are they included in Line 01 (Recording Fees)? Does it matter if they are the seller’s responsibility?

Yes, all per-page recording fees will be totaled and entered in the respective columns on a single line: Line 01 (Recording Fees), even those which are the responsibility of the seller.

Any costs payable by the borrower for recording additional documents will be added to the itemized charges for recording the deed and mortgage and the total will be disclosed in the borrower’s column. Similarly, costs payable by the seller for recordings will be disclosed as a total in the seller’s column on the same line and will not be separately described.

If you wish, you may show a complete itemization of recorded documents on an additional page as a “customary recital.” In DoubleTime®, the Recording Worksheet found under the Reports Tab serves that purpose.


Do e-recording fees paid to a third party get lumped in with all other recording fees on Line 01 (Recording Fees) of Section E (Taxes and Other Government Fees)?

Since Section E is reserved for payments to state and local governments it is unlikely that lenders will disclose these fees in that section since they are not paid to government. Instead, the proper location will likely depend on whether the lender authorizes or requires the use of e-recording services.

If required, they should be disclosed within the same table as the lender’s title insurance premium. If authorized, but not required, they should be considered an elective service which would be disclosed within the table H. (Other).

Note also that under an interpretation of Florida law e-recording fees are arguably a component of the settlement fee when the use of such a service is not required by a lender.


What if there is an error in disclosing closing costs? For example, what if a seller is charged for documentary stamps but it should be buyer’s expense? Does the three-day period restart?

Changes to the amount of documentary stamps or the party paying the stamps are not changes which require a new three-day waiting period. They will necessitate a revision and re-distribution of the Closing Disclosure so inform the lender of the correction as soon as possible.

Does a change to closing costs or change in cash to close require a revision to the Closing Disclosure to restart the three-day period?

Changes to closing costs or cash to close will require a revision to the Closing Disclosure, but will not automatically require a restart of the three-day delivery clock.

If the change is accompanied by either an increase in the APR above the legal limit, a change in the loan product, or the addition of a prepayment penalty, it is that change which will cause a restart of the clock.


In certain circumstances, a charge attributable to Buyer may become apparent after CD has been delivered (i.e. HOA fee attributable to the Buyer). How will the lender learn of this and will such a change require a new three-day waiting period?

A change in an HOA fee alone will not require a new three-day waiting period. A new three-day wait is only required when one of the following occurs:

  • Change in the Annual Percentage Rate (APR) as calculated by the lender
  • Change in the loan product offered to the consumer
  • Addition of a prepayment penalty to the loan product.

The lender will learn of changes when the settlement agent provides this updated information using the means of communication recognized by the lender. Many lenders are indicating they will use third-party cloud-based software such as Closing Insight to communicate with settlement agents.


Will the Lender answer shop or not shop questions or is closing agent to determine these issues?

The lender will answer the shop or not shop questions. The lender is responsible for the Closing Disclosure and will determine the placement on the form of your fees and charges.
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