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#972332 - 06/10/08 04:17 PM In House Evaluation Fee - Finance Charge?
complygirl Offline
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midwest
The Bank completed an in-house Evaulation on a real estate property securing a HELOC. Would this charge (which is similar to an appraisal fee) be considered a finance charge? I know appraisal fees are considered finance charges, but I wasn't sure about an in-house evaluation fee. Thanks.

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#972343 - 06/10/08 04:29 PM Re: In House Evaluation Fee - Finance Charge? complygirl
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Quote:
I know appraisal fees are considered finance charges


Appraisal fees on real estate secured loans are not considered finance charges. Neither would your in-house evaluation fees. See 226.4(c)(7) and its Commentary.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#972355 - 06/10/08 04:45 PM Re: In House Evaluation Fee - Finance Charge? Dan Persfull
complygirl Offline
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midwest
I didn't read far enough into the reg. Thanks for clarifying Dan.

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#973390 - 06/11/08 07:57 PM Re: In House Evaluation Fee - Finance Charge? complygirl
MyKidsMom Offline
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Along the same lines, you can't charge for an evaluation done by a bank employee, on a RESPA covered transaction, right? But its OK on an owner occupied construction, bridge or investment property... Am I thinking right?

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#973415 - 06/11/08 08:23 PM Re: In House Evaluation Fee - Finance Charge? MyKidsMom
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
RESPA does not prohibit you from a charging an in-house evaluation fee. You simply disclose it on the HUD the same as you would an appraisal fee.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#973422 - 06/11/08 08:30 PM Re: In House Evaluation Fee - Finance Charge? Dan Persfull
MyKidsMom Offline
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MyKidsMom
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I guess what I was thinking is that if you charge for it, you have to be able to document the cost of preparing it? Is that right or am I just losing it?

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