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#2030791 - 07/30/15 04:20 PM Loan Withdrawn - Appraisal Copy and Charge
complygirl Offline
Platinum Poster
Joined: Oct 2004
Posts: 822
Bank ordered and obtained an appraisal on a property and then later the application was approved but not accepted by the borrower. Under the Reg. B rules we are still required to provide the borrower with a copy of the appraisal, correct? And can we attempt to collect payment for the appraisal from the applicant? I know we can't charge for a copy of the appraisal, but can't we try to collect payment from the applicant for the actual appraisal that was completed? And a copy of the appraisal must be provided regardless of whether or not the applicant paid for the appraisal or not, correct? Thanks.

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Lending Compliance
#2030796 - 07/30/15 04:33 PM Re: Loan Withdrawn - Appraisal Copy and Charge complygirl
NSF, CRCM Offline
Gold Star
Joined: Apr 2013
Posts: 410
1) You have to send them a copy promptly after completion whether they pay or not.

2) You are correct that you can't charge them for the copy.

3) But you can try and collect for the cost of the appraisal. Nothing prohibits this.
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2030850 - 07/30/15 06:42 PM Re: Loan Withdrawn - Appraisal Copy and Charge complygirl
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
Episodes like this have convinced many lenders to collect the appraisal fee in advance, in connection with the applicant's notice of intent to proceed.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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