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#1746465 - 10/03/12 09:54 PM Appraisal Fee
Patricia Offline
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Joined: Mar 2011
Posts: 327
Kansas
The bank I am working at deducts the appraisal fee from the loan proceeds. I have never seen this practice before. Just wondering if any other banks are doing this.

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Lending Compliance
#1746518 - 10/04/12 12:46 PM Re: Appraisal Fee Patricia
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,418
Bloomington, IN
It's done all the time although the practice may change with the new Reg B proposal. I would suspect banks will most likely start requiring the appraisal fee be paid up front due to the proposed changes.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1746541 - 10/04/12 01:16 PM Re: Appraisal Fee Patricia
Patricia Offline
Gold Star
Joined: Mar 2011
Posts: 327
Kansas
Thanks Dan.

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#1760942 - 11/27/12 03:54 PM Re: Appraisal Fee Patricia
YosemiteSamIAm Offline
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Joined: Jan 2004
Posts: 2,795
Guess
Dan, what about the issues raised under TILA which prohibits even the collection of checks or credit card info prior to the delivery of disclosures to the customer? What would be the workaround other than having the customer come back after the 3 day period has run?
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#1760993 - 11/27/12 04:45 PM Re: Appraisal Fee Patricia
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,418
Bloomington, IN
That will depend on how your shop operates. If you hand the disclosures to the applicant face to face there is no prohibition from requesting the fees at that time. If you mail the disclosures you simply put a statement in your cover letter the appraisal fee must be paid by a certain date or no further action will be taken.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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