If Bank will be completing an in-house evaluation (opposed to obtaining an appraisal from a third party) where does this fee need to be itemized on the GFE? Block 1 (as part of the "origination charge" or in block 4 (where the appraisal fee would normally be disclosed)?

In house appraisals/inspections, etc, all go in the origination charges.

Do you breakout the appraisal on the HUD1 if it is in the origination?

No. All fees charged by the lender are included in the origination charges and are not to be further broken out.

We would like to begin charging an evaluation fee. Included in this fee would be the cost of pulling a AVM. Is this ok? We will pull an AVM (which doesn't usually return a hit, and only charges a fee of $20 if there is a hit), we conduct a site visit and take photos, and we complete an evaluation using any additional information we can obtain.

Can we charge a flat fee, regardless of whether or not we get an AVM hit?

Or do we need to itemize the AVM charge on the GFE and HUD since the fee utlimately goes to a third party?

Federal regulations do no prohibit you from charging an in-house evaluation fee however you need to check state law.

The fee you charge will be shown in Block 1 of the GFE and Line 801 of the HUD. The fee is not itemized.

Under 226.4(c)(7) the fee would be excluded from the finance charge but it would be included in the HOEPA fees and charges test.