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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?
If esign was properly executed, would receipt of acknowledgment from only one borrower be sufficient to start the counter for closing?
If the Initial ARM disclosure list the margin, index the loans is tied to, how often the rate can change, initial interest rate, the rate max increase/increase at one time, the rate ceiling, a payment example based on $10,000 at the initial rate, and a payment example based on the maximum interest rate, in your opinion, would this be compliant?
In the past, I always understood the initial ARM disclosure was an estimate, but recently it seems they are expected to match exactly. If the floor in the initial ARM disclosure is less than the floor in the contract (promissory note), I have heard of cases where the examiners are making banks remove or adjust the floor to match the initial ARM disclosure in these situations.
