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#2145736 - 09/12/17 04:45 PM Appraisal Fee Question
swiggles Offline
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...possibly a very elementary question.....

We use a third party vendor to order appraisals. The third party vendor also reviews the appraisal and charges a fee for doing so. Must this be broken down on the LE and CD as two separate fees?......appraisal fee to the appraiser and review fee to the vendor?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2145740 - 09/12/17 04:56 PM Re: Appraisal Fee Question [Re: swiggles]
rlcarey Offline
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Two separate services with two separate fees, I think equates to two lines on the LE and CD.
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#2145747 - 09/12/17 05:25 PM Re: Appraisal Fee Question [Re: swiggles]
swiggles Offline
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They are showing the appraisal fee payable to the vendor, not the actual appraiser. I know that wasn't OK under RESPA (ultimate recipient of the charge), but is it OK now?
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#2145751 - 09/12/17 05:56 PM Re: Appraisal Fee Question [Re: swiggles]
rlcarey Offline
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From the preamble to the final regulation:

Several national trade association commenters representing real property appraisers, as well as a number of individual appraiser commenters, stated that any charge for an appraisal management company (AMC) should be required to be separately itemized in § 1026.37(f)(2). As noted in the Bureau’s proposal, section 1475 of the Dodd-Frank Act permits the optional disclosure of the charges made by an AMC, but does not require separate itemization. See 77 FR 51116, 51134 (August 23, 2012).

However that is talking about the appraisal and not additional services.
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#2145784 - 09/13/17 09:25 AM Re: Appraisal Fee Question [Re: swiggles]
swiggles Offline
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I read 1026.37(f)(2) and its commentary....then your reference above. So this is saying that the fee for the appraisal CAN be shown payable to the AMC, not the actual appraiser?

And so there should be two fees....an appraisal fee and a review fee, separately itemized under services for which the borrower cannot shop?

Sorry for my denseness.
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#2145788 - 09/13/17 09:35 AM Re: Appraisal Fee Question [Re: swiggles]
RR Joker Offline
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That's how I understand it, Swiggles. Each service provided would have it's own line.
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#2145792 - 09/13/17 09:46 AM Re: Appraisal Fee Question [Re: swiggles]
swiggles Offline
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LOL...yes, but can the appraisal fee be shown as payable to the appraisal management company (our vendor) rather than to the actual appraiser? That is my remaining question.
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#2145798 - 09/13/17 09:59 AM Re: Appraisal Fee Question [Re: swiggles]
rlcarey Offline
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Yes - you have no control over who they pay what. Similar to a pass through fee by the title company. You show who you cut the check too.
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#2145799 - 09/13/17 09:59 AM Re: Appraisal Fee Question [Re: swiggles]
RR Joker Offline
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This ^^^
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#2145811 - 09/13/17 10:02 AM Re: Appraisal Fee Question [Re: swiggles]
swiggles Offline
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Bless you all. Thank you for your valuable advice.
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#2145908 - 09/13/17 03:27 PM Re: Appraisal Fee Question [Re: swiggles]
swiggles Offline
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This thread seems to say the opposite.....itemization NOT required. Now, I am further confused.
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#2145912 - 09/13/17 03:34 PM Re: Appraisal Fee Question [Re: swiggles]
rlcarey Offline
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Loc: Galveston, TX
Well it depends - are there one or two fees??
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#2145964 - 09/13/17 05:42 PM Re: Appraisal Fee Question [Re: swiggles]
swiggles Offline
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Their invoice indicates a fee for the appraisal and a fee for the review. Is that the key?
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#2145968 - 09/13/17 05:53 PM Re: Appraisal Fee Question [Re: swiggles]
rlcarey Offline
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Loc: Galveston, TX
I think it is. If they were doing both for one fee, then I think you combine it as an Appraisal/Appraisal Review Fee. Since they are separating the services, I think you have to itemized them. In that post that you linked, I don't think I focused on the two separate services and was thinking about the appraisal fee/AMC fee being combined without considering the separate review fee.
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#2145974 - 09/13/17 06:17 PM Re: Appraisal Fee Question [Re: swiggles]
swiggles Offline
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Thanks, Randy. You are big help.
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