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#1185374 - 05/18/09 03:45 PM HVCC/taking applicant's credit card for appraisals
Many Hats Offline
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Orlando, FL
We are a small community bank and typically broker our residential mortgage loans to other wholesale investors (i.e. Taylor, Bean & Whittaker). They have instructed us to begin collecting the applicants credit card information (name, number, exp date & CSV code) prior to an appraisal being ordered.

I am not comfortable with this process.

Has anyone else encountered this yet and if so, how are you handling it?

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#1185503 - 05/18/09 05:14 PM Re: HVCC/taking applicant's credit card for appraisals Many Hats
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I've not heard that from any of our secondary market lenders...at least not yet.

they may be doing this because of all the changes and attempting to make sure they end up getting paid.

So, curiously...what do you do with an applicant who has no credit card??
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#1185518 - 05/18/09 05:22 PM Re: HVCC/taking applicant's credit card for appraisals RR Joker
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Or flat out refuses to provide?
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#1185541 - 05/18/09 05:36 PM Re: HVCC/taking applicant's credit card for appraisals Skittles
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Gosh...since the new Reg z changes prohibit us from taking a fee until after the early disclosures have been sent it appears that they just trying to get around this? It then appears to fly in the face of the spririt of both the Reg z changes and of the HVCC.
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#1185543 - 05/18/09 05:40 PM Re: HVCC/taking applicant's credit card for appraisals QCL
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I dont' think that's the reason, QCL...think about it. You simply can't collect anything but the credit report fee until you've disclosed. That means as soon as they sign the dotted line (face-to-face) or receive it in mail and send back with a check for $x.xx for further processing of request, you can collect...I don't see any acutal huge change there.

There is too much contradiction...if the first 7-day wait is for shopping purposes, it would have made more sense to not go futher into processing until day 7...for fee collection or anything else for that matter.
Last edited by RR joker; 05/18/09 05:42 PM.
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#1185547 - 05/18/09 05:46 PM Re: HVCC/taking applicant's credit card for appraisals RR Joker
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True.
Good point.
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#1185574 - 05/18/09 06:23 PM Re: HVCC/taking applicant's credit card for appraisals QCL
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So is it too early to ask how you're going to handle stuff like this JLJ or QCd'L? Personally waiting till day 7 to even start makes sense per the Reg but it's going to boil LOs and borrowers alike, especially those who've shopped before they even came in the door.

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#1185592 - 05/18/09 06:37 PM Re: HVCC/taking applicant's credit card for appraisals Truffle Royale
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That won't happen because the smartypants in Washington didn't write it that way...it's just that it misses the point, IMHO! Simplist thing to do? Fill out disclosure, hand it to borrower..."ya want the loan"? Okay, sign the dotted line and hand over the cash! Then we'll talk about it! wink

LOLOL! That's actually how it used to be done! wink
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#1185626 - 05/18/09 06:54 PM Re: HVCC/taking applicant's credit card for appraisals RR Joker
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Their request probably has to do with trying to prevent payment being made by the client directly to the appraiser or the third party originator who may not have ordered the appraisal. HVCC strictly prohibits the client from direct payment to the appraiser.
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#1185651 - 05/18/09 07:12 PM Re: HVCC/taking applicant's credit card for appraisals OldSchoolBanker
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We are just not comfortable with collecting an applicant's credit card info. We will either require they pay us via cashier's check or money order, or if they have an e-mail address, TBW will send them a link to pay online through their web site.

I am just waiting for an applicant who gets turned down after having paid for an appraisal to dispute the charge with the cc company. Is the lender going to expect us to pay for it? Or, worst, someone accuses one of our employees of selling their credit card info......etc. Nope...not going there!

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