HUD's Q&A #9 on page 28 indicates we should include "...obtaining verifications & appraisals" in block 1 of the GFE.

We pay a set fee of $330 to an appraisal management company that covers the cost of ordering the appraisal, the actual appraisal, reviewing the appraisal, etc. The AMC contracts out the appraisal and the amount the AMC pays to the individual appraiser varies. However, the bank always pays $330 to the AMC.

Based on HUD's Q&A, do we have to breakdown the $330 that the bank pays to the AMC into separate amounts (box 1 amount for ordering) and box 3 amount for the actual appraisal & review of the appraisal)?

We've been disclosing the total amount of the $330 and not breaking it down. An examiner is stating this is incorrect and we need to break down the $330 and include a portion in block 1.

Can anyone point me to a Q&A or any other guidance that will help me resolve this issue?

Thanks.

See page 49 of the HUD FAQs #8.

That FAQ pertains to the lender performing those functions, not a 3rd party.

We use an AMC on some loans and we break out what the appraiser is paid vs the AMC company (for the review of the appraisal).