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?

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!