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#2171342 - 04/02/18 05:58 PM Appraisal Ordering Service - Finance Charge
Tryin2Comply Offline
Joined: Aug 2014
Posts: 76
For residential mortgage appraisals, we are looking into using an appraisal bidding/ordering platform. It is not an AMC because bank personnel select the appraisal and what not (I can elaborate if needed). This company will charge a 4% fee for their services. We would like to pass this fee on to the customer and I am trying to figure out if and how we can pass the fee along. Here are the questions I've had:

-Will the 4% fee be a finance charge? I believe it will under 1026.4. Appraisals are excluded from finance charges if they are reasonable and bonafide, but I don't think this would be excluded.

-We should disclose the 4% fee and the appraisal fee separate in services the customer cannot shop for?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2190058 - 08/22/18 02:14 PM Re: Appraisal Ordering Service - Finance Charge Tryin2Comply
Banker K, CRCM Offline
Gold Star
Joined: Jan 2010
Posts: 290
Hi there @ Tryin2Comply, what did you wind up doing in this situation?

Our construction appraisals are ordered through a vendor and they charge an appraisal ordering fee.
We disclose it separately from the actual appraisal fee and make it a finance charge.
They are both listed in the same area "services you canNOT shop for".

If anyone has other feedback I would also appreciate it - thanks!
Compliance - A Painful Addiction

All comments are mine & should not be taken as legal advice.

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