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Third-Party Appraisers: Commercial Loan

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Question: 
We are third-party appraisers. We saw something that we have never seen before. We have a bank that is charging a customer $3000 for a commercial loan appraisal, while we were charging the bank $1800. At the very least we thought there should be some sort of disclosure that there is fee income to the bank in that pricing structure. This is a commercial loan, not a consumer loan. We are aware that the disclosures do not apply for many items, But should not fee income to the bank, versus a actual pass-through fee be shown?
Answer: 

Any sort of required disclosure on a commercial transaction would be governed by State law. In the States in which I have worked there are no real commercial disclosure requirements. The Bank may also be adding in any costs for the appraisal review or other administrative duties associated with validating the appraisal. Whether the fee is unconscionable is a matter between the commercial customer and the bank to negotiate.

First published on 10/02/2016

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