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I have a question about title insurance disclosures for a business purpose loan secured by a 1 – 4 family dwelling. We use Title Center of Greater KY for almost all title insurance written on our real estate loans. We typically give 2 titles insurance forms for these particular loans. (Notice of Free Choice of Agent and Insurer AND Disclosure With Respect to Title Insurance). When I review loans I will see that these 2 particular documents are not signed by the customer or they will be dated the day of closing. Is it in regulations that these 2 documents are to be given on these type of loans? And if so, at what point of the loan are these required to be given? I would assume within 3 business days of loan application but one of my loan officers wants to know if there is something in regulations stating this. I am trying to figure out if there would be a compliance violation doing it their way.
If none of the fees are affected/changing by adding the past due bill to be paid or say a judgment lien that will be paid from the closing is there still a requirement to redisclose the Loan Estimate? I know this would be a changed circumstance but it could not even change any of those fees but it would change the cash to close amount.
