What I THINK you are describing is that there is a policy when the developer purchased the parent parcel and since that time it has been divided into lots.  For us, it depends on the length of search and whether or not we were the ones who performed the search which is the basis of the title policy.   If the developer is still the owner of the lots and we are just updating them with new TMS #s and such, we charge the current owner fee.  If there are subsequent owners, we charge a developer fee.