DO WE HAVE TO LIST AN APPRAISER ON A GOOD FAITH ESTIMATE IF WE DO NOT REQUIRED IT?????? ANY HELP ON THIS WOULD BE GREATLY APPRECIATED. ASAP PLEASE AND WHERE IN THE REGS DOES IT SAY THAT WE MUST PROVIDE THIS IF LENDER DOES NOT REQUIRE IT....

THIS IS MY OPIONION AND NOT MY EMPLOYER!

First - don't shout. Second, if you are not going to require the use of an appraiser, why would you be listing an appraisal fee to begin with????

Sorry, still a little slow today. Are you referring to an appraisal fee on the GFE if you don't require an appraisal?

Exactly, if that's the case,if an appraisal is not required, then you don't need to put it on the GFE

I didn't mean to shout. On the Good Faith Estimate we do not list specific service providers. The examiner is saying we have to list a specific service provider. We are looking at 24 CFR 3500.7 (e), and we interrupt it as, if we do not require a specific provider we do not have to list anyone. The examiner is saying that Reg X states a specific service provider has to be listed.

Any guidance or support would be greatly appreciated!

The opinions expressed are my own and not my employer.

See 3500.2 Definitions "Required Use" The way we interpret this is if we don't require the customer to use a particular provider, eg.appraiser then we don't list them (appraiser) on the GFE, only the amount

If you are not requiring an apprasial, then one does not have to be listed. But, if you are requiring an appraisal, then the appraiser needs to be shown.

If you know who the appraiser will be you should list them by name. If you do not know who the appraiser is at the time of the GFE (and providing you maintain a list of 5 or more appraisers) there should be a statement similiar to: For Line 803 an appraiser will be chosen from a lender controlled list.

Just to satisfy my curiosity...

What if you require an appraisal, but the borrower can use any appraiser of their choosing. You won't know who they'll select at the time of GFE - what would you disclose.

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What if you require an appraisal, but the borrower can use any appraiser of their choosing.

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We won't allow this. They have to choose an appraiser from our approved list of appraisers or we will choose one if they do not.

If you allow them to choose their own appraisers (and not from your list), then I suggest you ask the applicant who they intend to use at the time of application.

Regardless who chooses the appraiser, if you are requiring the appraisal then you either have to list the appraiser by name (if you know who they are at the time the GFE is given), or you have to give a range of prices based on the pricing of the appraisers on your approved list.

The FDIC has consistently interpreted Reg X in this way. If you use the same service providers over and over, you had better list them in an addendum. It appears you are requiring an appraisal be obtained acceptable to your bank. And if you have a list to choose from then you need to list an appriaser. You will lose this arguement, so why make the examiners mad ?

Your safety and soundness examiners would have a fit if you allowed borrowers to pick their own appraisers - not to mention that I would be right over for a loan.