Our bank is weighing the benefits of using an AMC for residential appraisal ordering and review against our current process for performing these functions in-house. The AMC charges a fee for appraisal review. Management has asked if the bank can charge its own fee for reviewing appraisals in-house. Compliance has responded that such a fee must be included in the bank's origination charge in box 1 of the GFE, and that the only way it can be itemized separately is if it is paid to a 3rd party. This appears to be a significant issue with management, and they do not want to increase the origination charge for competitive reasons. First, I want to make sure this interpretation is correct. Secondly, I want to see if anyone (who does not use an AMC) has found a way to deal with this issue in a way that we have not thought of. I appreciate any feedback. Thank you.

Your compliance department is absolutely correct. Your in-house appraisal, credit or whatever review fee would be part of your origination charge. No way around it.