[twool23]

When providing a Loan Estimate, if you know a fee that is typically associated with the type of loan being applied for is not going to be charged such as a (using previous) appraisal. How would you list the appraisal or would you list the appraisal on the loan estimate?

Back in the day, with the GFE there was guidance stating you would list the appraisal but list it as $0. However, I’ve been unable to find any guidance under TRID addressing the situation.

Thanks!

[rcooper]

You are required to disclose the costs associated with the transaction (see 19(e)(3)(I), 37(f)). If you know for certain you will not be obtaining a new appraisal then you would not include the fee on the LE. If there is any chance that you will be ordering a new appraisal I would suggest that you include the fee.

[JGo9]

To handle this situation at my bank we always list the fees typically associated with the type of loan applied; even if we anticipate at the time of disclosure not charging for something such as an appraisal, to avoid the potential pitfalls Robin has warned about.

Once we get to the Closing Disclosure (CD) if we did not charge for a fee(s) we had listed on the Loan Estimate (LE) we have the fee(s) fall off. This gives the bank some added flexibility, in case we bank change our mind about charging a fee for whatever reason. We feel this provides the bank with the best protection; which I think Robin was alluding to.

Robin, don’t let me put words in your mouth, so if you disagree let me know.

Thanks!

[Author]

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