We have a CIC being a changed loan amount. Can this CIC allow us to capture a new charge? Customer is doing a bridge type loan. They were going to evaluate the current residence and appraise the new one. Now they are appraising both. Are we able to disclose the new fee for the second appraisal on the new LE due to a CIC?

Thank you.

Yes, if the consumer requested a change in the credit terms.

Who is they?

Ok, just leery about changing charges after already being disclosed.

I'm asking because it shouldn't be up to the borrower to decide whether the bank is going to do an in-house evaluation or an appraisal, and if "they" represents the loan officer, changing your mind isn't a valid changed circumstance.

Sorry for that. "They" is the bank, not the customer.

The new loan amount is the changed circumstance. Just wondering if we can capture the new charge for the second appraisal with the new LE.

The only way i can think of that being "kosher" would be if the requested increase put your loan amount over the $250,000 threshold, thus requiring a certified appraisal. Otherwise, no, the borrower asking for more money doesn't give you carte blanche to increase fees that are unrelated to the increased loan amount.

I would take a differing opinion if the increased loan amount increased the LTV to where the bank felt an appraisal vs. an evaluation was needed to support the increased loan amount.

We will do an evaluation if the LTV is 75% or less. But if we feel the property has deteriorated based on our inspection or if the borrower increases the loan amount where the LTV will exceed 75% then we will require an appraisal and we will revise our appraisal estimate.

1. The deteriorated property is an unknown condition at the time the original LE is issued.
2. The increase loan amount is an applicant requested change that increases the LTV which changes information relied on to issue the original LE.

Actually the loan amount started at $300,000 and went up to $330,000.

Dan, that makes sense.....i just didn't want to assume facts not presented. I can agree with that logic; i just wanted to point out that a customer requested increase in the loan amount isn't a free pass to change an unrelated fee. As your post points out, it CAN be related.

I agree^^ When we take both houses it is common for us to do an internal evaluation depending on the LTV, etc. on the home they already own. If the customer requested a higher loan amount we would consider that a customer requested change. I should have asked more questions before answering.