Thread Options
#2204723 - 02/01/19 03:08 PM increased appraisal cost-CIC?
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
I think I know the answer, but just for arguments sake: Loan amount was $1.4 million, we quote $450 appraisal. Actual appraisal cost came in over $950. Can this be considered CIC or should have known that the appraisal would have been higher and quoted a higher cost on our LE?

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2204725 - 02/01/19 03:15 PM Re: increased appraisal cost-CIC? mdog76
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 542
RVA
What was the reason (the change that occurred) that the appraisal was higher than what you estimated?

Return to Top
#2204726 - 02/01/19 03:16 PM Re: increased appraisal cost-CIC? mdog76
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,622
Based on what you provided, I don't see a changed circumstance. A change in the appraisal price alone is not a changed circumstance.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2204728 - 02/01/19 03:28 PM Re: increased appraisal cost-CIC? mdog76
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
I agree with Adam. We just quoted our appraisal price on the LE too low in this situation. The loan officer didn't take into account the larger, more complex property and quoted our standard appraisal charge. They were hoping it could be a CIC, but nope!

Return to Top
#2204731 - 02/01/19 04:01 PM Re: increased appraisal cost-CIC? mdog76
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
I agree it's not a CC.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#2204855 - 02/01/19 10:13 PM Re: increased appraisal cost-CIC? mdog76
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
Definitely not a changed circumstance.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2204866 - 02/01/19 10:56 PM Re: increased appraisal cost-CIC? mdog76
Hawk Offline
Member
Joined: Jan 2019
Posts: 56
Even with an appraised value over a million you should have known it would be more than an average appraisal. Definitely not a COC.

Return to Top