1. If we are using an existing appraisal from another bank, are we required to disclose an appraisal fee on the GFE?

2. If the existing appraisal is deemed to be unacceptable - can we issue a revised GFE to reflect the cost of getting a new appraisal? (Is this a valid change in circumstance?)

3. What if we are doing a 2nd using the same appraisal as our in-house mortgage department obtained - should both GFE's list the fee?

Thank you.

1. Yes - it was required, same as if you used a previous one in your own file.

2. I would think it would be as it would be unknown info to you at the time of acceptance. It may be moot if the fees are the same, however.

3. I'd have to think longer on that one!

1. Yes, if an appraisal is a common requirement of the loan type applied for.

2. No, because if an appraisal is a common requirement of the loan type it should have already been disclosed.

3. If both loan types require an appraisal then both should reflect the fee.

Remember, the GFE is worst case and if an appraisal is required then an appraisal is required, regardless of how it was aquired, you should disclose a fee.

1 & 3. See the December 2010 RESPA Roundup:

http://portal.hud.gov/hudportal/HUD?src=/program_offices/housing/rmra/res/resroundup


2. See page 20 of the RESPA 2010 FAQs. You might be able to stretch it into an updated appraisal requirement but honestly I'm not sure I would rely to heavily on that. It's not the applicant's fault you got a bad appraisal.

You might want to consult the FNMA 5/2010 bulletin regarding the (in)ability to reuse an appraisal if there's any chance you'll be selling this loan.

Thanks everyone.