RESPA - Appraisal

Good Morning.

I'm sure this has been asked before, but I'm having trouble finding an answer. If a customer goes into ABC Bank and gets an aapraisal, then brings the Appraisal to XYZ Bank (us) and we decide to use it, how would we put this on the GFE and the HUD-1A? Since we are not charging the appraisal fee, and it's not a service we selected or they could shop for, where would it go?

Any help would be great!
Thanks!

First thing first - I do not believe that accepting an appriasal from the applicant is acceptable under the appraisal guidelines - it would have to come from the regulated institution or from a financial services institution:

"A regulated institution may accept an appraisal transferred from another regulated institution or from a financial services institution (that is, a non-regulated institution), provided 1) the appraiser is engaged directly by the institution transferring the appraisal, 2) the appraiser has no direct or indirect interest in the property or transaction, 3) the existing appraisal or evaluation remains valid, and 4) the regulated institution determines that the appraisal conforms to the agencies’ appraisal requirements and interagency guidelines and is otherwise appropriate. (A financial services institution describes entities that provide services in connection with real estate lending transactions on an ongoing basis.)

Regulated institutions are expected to perform a more thorough review when accepting an appraisal from another financial services institution to confirm that the appraisal complies with the regulation and has sufficient information to support the lending decision. Moreover, the regulated institution accepting the appraisal should determine whether appropriate documentation is available to confirm that the financial services institution (not the borrower) ordered the appraisal."

We received the appraisal from another regulated institution. Then how would we put that on the GFE and the HUD?

you will show the cost on the GFE and show it POC on the Hud...explain that to your borrower.

Thanks! That's what we thought.