No charge, no delivery of appraisal?
by John Burnett, BOL Guru Guru BIOS
Question:202.14(a)(2)(ii) states that a bank does not have to provide an appraisal until after it has received reimbursement from the applicant. Can a bank simply not charge for the appraisal and then refuse to provide it? The sample notice says nothing about the applicant paying for the appraisal.
Answer: The regulation says a creditor shall provide a copy of the appraisal. The sample notice is a starting point, and you can certainly state in your notice that the applicant must pay up to get the appraisal.
On the other hand, if you state in your ads or promotional material that the appraisal is free, I don't recommend turning around and demanding payment as a condition precedent to deliverying the appraisal copy. If you advertise no charge appraisals, I suggest you disclose an exception in the event the applicant asks for a copy, or give up the copy at no charge.
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