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#2086601 - 07/05/16 04:22 PM Appraisal Fee/Lender credit?
MonicaMc Offline
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MonicaMc
Joined: Dec 2013
Posts: 238
Land of Oz
We are starting to use a new appraisal software where we are self-managing. Big change from our previous AMC. Our new process will be to collect the set appraisal fee from the borrower (after receiving intent to proceed) and deposit it into a mortgage bill pay account. Then the appraisal will be ordered and randomly assigned. At closing, the appraisal fee will show as being paid to the appraiser but paid by the Lender in Section B. Every 30 days, we will batch pay appraisers from said bill pay account.

Does this all sound compliant? Do we need to show a Lender credit on the LE for the appraisal even though we won't have collected the fee at that point?

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#2086612 - 07/05/16 04:58 PM Re: Appraisal Fee/Lender credit? MonicaMc
NorthernAnalyst Offline
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NorthernAnalyst
Joined: Aug 2015
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United States
If you are collecting the appraisal fee from the borrower then passing it on to the appraiser at a later date, doesn't that constitute a borrower paid fee, not a lender paid fee?
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Not legal advice. Not the opinion of my employer.

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#2086622 - 07/05/16 05:37 PM Re: Appraisal Fee/Lender credit? MonicaMc
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
doesn't that constitute a borrower paid fee, not a lender paid fee?


Yes.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2086624 - 07/05/16 05:41 PM Re: Appraisal Fee/Lender credit? MonicaMc
MonicaMc Offline
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MonicaMc
Joined: Dec 2013
Posts: 238
Land of Oz
So we would leave it as a borrower paid before closing fee since they are paying their requirement of the appraisal fee before closing. So no lender credits.

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#2086628 - 07/05/16 05:50 PM Re: Appraisal Fee/Lender credit? MonicaMc
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
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Bloomington, IN
No where in your original post is it indicated you are giving the borrower a credit for the appraisal fee. You are collecting it from the borrower and paying it to the appraiser at a later date, which is what most FIs do when they collect the appraisal fee up front and pay the appraiser when the appraisal and bill is received.

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#2086636 - 07/05/16 06:36 PM Re: Appraisal Fee/Lender credit? MonicaMc
MonicaMc Offline
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MonicaMc
Joined: Dec 2013
Posts: 238
Land of Oz
Thank you! I think we were just thinking about it too much and making it harder on ourselves than it needed to be!

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