I'd love to hear opinions on changed circumstances as they apply to credit reports and appraisals. Typically, we estimate a basic credit report or appraisal charge. However, things can occur during the loan process that result in additional charges.

In your view, if an additional fee is charged for an appraisal due to the location or complexity of the property, or for the credit report due to trade line updates, are these changed circumstances permitting a new LE?

Location (appraisal) - No, it's one of the 6 application items. You know it and need to account for when estimating fees relative to any service you outsource to a 3rd party. There's a reason the the regulation uses the term "Good Faith" in relation to the accuracy of the Loan Estimate.

Complexity (appraisal) - Maybe, if the appraiser goes out says repairs are needed, then yes. If it's a million dollar home and you didn't account for that being a more complex appraisal, the answer is no.

Credit Report - Maybe, depends on the exact details as to why an update was required.

Jerod, thank you for the response. To follow up, the appraisal issue often pops up when our AMC selects an appraiser who is further away from the property than another appraiser who is on the list (they use a round robin selection). Therefore, though we may know where the property is and not consider the location to be remote or worthy of enhanced fees, the appraiser selected my disagree, based on THEIR location.

On the credit report issue, my question is about situations where there are things that don't appear on the report, but should.

I would consider new debts incurred by the borrower (such as a loan to furnish the new home) that were not on the 1003 or original credit report but we learned of later and needed trade line updates for to be valid changed circumstances.

Unfortunately it's your problem and you'll have to get it figured out. You're choosing to outsource the service and therefore you have to nail down the estimated cost, in this case to the exact penny as it's a 0% tolerance item.

Still thinking about the credit report info. I'll get back to you.

Appraisal - I agree. Your AMC is not going to get away with that in the future as every client is going to demand a locked down price. Their scheduling issue should not impact you and someone needs to tell them that.