We are thinking of accepting a credit card for the borrower's CBR and Appraisal. What do we need to do? I know that it is OK to charge for the CBR report and that we cannot charge for the appraisal until after the early disclosures have been received. What kind of procedure are you using to ensure confidentiality of this credit card information collected? What else should I be thinking about before this can happen?
Thanks so much for any responses!!!

until after the early disclosures have been received.

I think you mean prior to receiving an intent to proceed.

There were many discussions right after the law was enacted, and at that point, the consensus was that it is OK to collect the credit card number for the CB.

It would however be against the intent of the regulation to collect the credit card information for the appraisal, even if it was not used until the proper time. The customer might feel obligated to complete the transaction because they gave you the number and authorized the appraisal.

In our shop, we aren't collecting the credit card info (or any other form of payment) for either the CB or the appraisal until after we've received intent to proceed. I know you can collect the CB fee; we've chosen not to as a 'convenience' to the applicant to not have to pay the fees separately...