[FirstNatl]

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.

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[rcooper]

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.

[kmeade]

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?

[Author]

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