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Should the fee for an independent appraisal review be considered a finance charge? It seems to meet the definition but also looks like according to comment 4 (c) (7) that it could be excluded.
I agree that under 1026.4(c)(7) the appraisal review fee to an independent third party would be excluded from the finance charge for a loan secured by real estate or a RMT if the fee is bona fide and reasonable.
An additional question on this topic, if under 1026.4(c)(7) the appraisal review fee is from an independent third party would it still be excluded from the finance charge for a loan secured by real estate and the cost is bona fide and reasonable, if the bank only charges an appraisal review fee on loan amounts or property values above a specific dollar amount?
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