If someone other than the borrower is paying the appraisal fee can we collect the fee upfront or do we need to wait until borrower provides intent to proceed after receipt of GFE?
I would say no for this reason: IMO that limits the borrower's ability to shop for a loan. They know the appraisal fee has already been paid by this 3rd party, so are they really going to feel like they can go to another lender and put this 3rd party out a couple hundred bucks? Also like other posters said you can't collect fees upfront until intent is received (although I can't remember if the regulation states that it's just the borrower you can't collect them from or anyone)
Even if the lender is paying it, I still say no. I may be overly conservative, but I don't let LOs order appraisals until intent has been received. Again, I feel like it limits the borrower's ability to shop when they know an appraisal has already been ordered.