We are using a third party appraisal review company for appraisals and appraisal reviews. We request the appraisal, and receive a copy of the appraisal and a review. We just noticed the appraisal contains language stating the fee to the appraiser, which is less than we are invoiced and collect from our borrower. The difference is for the Appraisal Management Company services, including the appraisal review. I immediately thought we should be disclosing the Appraisal Management fee separately. Any thoughts?

From the original TRID preamble:

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).