We have a "No Fee" HELOC program where the customer pays no fees. On the Appraisal Disclosure notice, can we inform the customer that if they want a copy of the appraisal, it will cost them $75 and have that still be considered a "No Fee" program?

Good question for your examiner. My opinion is that since the appraisal is optional, the answer would be no. But I wouldn't bet my job on it.

Reg B gives you two options - to routinely provide a copy of the appraisal or to give the appropriate notice. What is your procedure? If you routinely provide the appraisal then IMO you must provide the appraisal to the applicant at no charge on no fee loans, otherwise IMO you cannot advertise it as having no fees. I would hold the same opinion if you provide the notice instead of routinely providing a copy.

We routinely provide the appraisal and we do so at no cost to the applicant for our "no fee" HELOCs.