I am having some issues figuring out how we should be disclosing appraisal fees on the LE and CD when we don't charge the customers.
For one region of our bank, all appraisals are done by third-party appraisers and our lending department is arguing that they do not need to disclose these costs on the LE because we do not charge the customer. They are citing the FAQs from the CFPB found here:
https://www.consumerfinance.gov/com...tegrated-disclosure-faqs/#lender-creditsIn question 3 it appears to state that if the creditor absorbs the cost, then they do not need to disclose certain fees. However immediately following that it states that if the creditor agrees to provide a lender credit sufficient to offset all of these charges then they need to disclose it on the LE. Meanwhile in question 4 it states that all of these charges need to be disclosed.
Additionally, would it make a difference whether the appraisals are done by a third-party or by a department of the bank?
Any help on this would be appreciated. Thanks.