If I am understanding correctly, we cannot estimate the cost of an appraisal on the GFE. Would the borrower sign a statement of “intention to proceed” and attached this statement to the GFE? Once the intention to proceed has been established, how do we disclose the appraisal fee, so to be in tolerance with the HUD?
You must include an estimate for the cost of the appraisal on the GFE, but you cannot impose the fee or obligate the borrower to pay the fee until the GFE is delivered and you have obtained evidence of the borrower’s intent to proceed with the transaction.