Refunding appraisal and credit report fees at close

Dan Persfull:

In addition to what Randy said - (client must pay the appraisal upfront, reimbursement will apply once the loan has closed). You don't mention the timing for when they have to pay upfront but you can't "impose" a fee, other than a reasonable fee for the credit report, prior to issuing the loan estimate and receiving the consumer's intent to proceed.

If the loan doesn't close and you don't give the consumer their fee back then as Randy indicates the appraisal is not free.

If the appraisal is truly free then why are your collecting the fee upfront?