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Please advise on below:
Our small local bank is looking into using a company to order/review appraisals for us. They charge an ordering fee ($25), as well as a review fee ($75). We would like to pass these fees on to the borrower, if possible. Are these fees able to be included in the appraisal fee line for LE/CD, or should they be itemized? Would they then be considered finance charges?
You would not lump these in with the appraisal. Since it a service they can’t shop for it must go in the zero tolerance bucket on the LE and the CD and clearly stated who the company. All fees are to be in alphabetical order. Since it is an Appraisal Service Fee you could list it that way and the fee as $100. They do not need to be separated into 2 lines. If they do not pay this outside of closing then it would be a finance charge.
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