We had a very weird situation where the applicant does not want a certain appraiser appraising his property. We bank in a very small community and do not have access to a multitude of appraisers. Do we let the applicant dictate who we don't use if they happen to be the next appraiser on our rotation?

No.

Applicant gets no say on who appraises their property. Is there a conflict and does the appraiser know about it? That might disqualify them from the assignment.

I go the other direction.

No, an applicant cannot choose who appraises their home, but at the same time if the applicant has a good reason for not allowing a certain appraiser/individual into their home (or even if they do not have a good reason), then I am not sending that person into their home. I'd just go to the next one on the list.

We have received very few requests over the years to not have a certain person or firm sent out, and generally they have all been very reasonable reason as why they do not want them in their home.

JustJay, how do you handle your appraisal fee on the LE if the next appraiser on your list charges a higher fee? Can that be considered a CoC with valid redisclosure?

I'm with Jay...if an applicant asks for a certain appraiser, we inform them that regulations won't allow that and we also make sure we don't send the requested appraiser.

Further, if someone asks to exclude an appraiser, we will let them exclude one appraiser/firm but we don't inform them of that option.

Why make a potential customer angry by sending someone they don't want?

Admittedly, we have a different situation different from the original poster in that we have at least 4 firms in every market territory where we operate.

I would say no but you have to make that determination for your shop.

We have fixed contractual pricing with all of our appraisers and firms who want our business, so not an issue for us anyways.

Again if it happened more than once or twice a year when we book 1000 apps a years, it would be unusual. just doesn't happen often.

We are quite limited in our appraiser pool in our major market area, so letting a borrower strike an appraiser would effectively reduce the appraiser pool by about 33%. I suppose my answer was with that in mind.

Thanks for all the reply's. This has been very helpful!

The more I ponder your question, the more confused I become. How are you selecting an appraiser form a rotation of appraisers in order to quote your LE, when you don't even intent to proceed yet because you have not issued your LE? Are you ordering appraisals before you even issue your LE and obtain intent?

So we're in a little bit different of a situation than you - we're booking more like 75 apps/year and there are only 2 originators. So we each rotate for our own loans between our 2 approved appraisers (who didn't give us fixed pricing :)). So on my LE, I quote whichever appraiser is next. Occasionally, I could order two appraisals in a row from one appraiser if the intent to proceed came late on an app, but it doesn't end up being an issue right now.

So in short, I pick the next appraiser due when sending out my LE. Appraisals are not ordered until intent is received. Hope that makes sense?

Why not just quote the higher of the two appraisers and make your life a little simpler?

...because I never thought about it . Is that all good with the reg, though? Aren't we supposed to make a good faith effort to disclose the costs as accurately as we can?

If it is all good, that would make life so much simpler...

There's a comment somewhere in the Readiness Guide that "good faith" is satisfied if the actual cost is equal to or less than the amount disclosed...

I could be 100% wrong here - but I thought that you couldn't "pad" prices. For instance, I couldn't way over disclose title work to avoid tolerance issues. Is that not right??

But you are not padding... you are disclosing up to a legitimate cost for which you will be consistently be charged, in your case nearly 50% of the time.

Padding would be flood determinations cost us $18, but I'll quote $25 anyways. Padding is quoting a higher fee you will either never have to pay, or pay in so few instances it is obvious to what you are doing (i.e. one time out of 200 hundred you might get charged an extra cost than quoted).

Gotcha! Thanks for the clarification . It certainly makes things easier now and we can issue LE's more efficiently!

I'd be in trouble if it weren't for this website.