[Vcorman]

@jholzknecht Thank you so much for a quick response. Could you please just advise if we are in compliance based on the scenario below, and if we can ask the borrower for appraisal fee re-imbuement.

“The appraisal was ordered 12/5, ITP signed 12/6, and the Mortgage Co. paid for the appraisal upfront.

I’m just confused at your answer because we have already ordered the appraisal before the ITP was sent and received by the borrower: “It appears you provided the disclosure and the borrower provided the intent to proceed. Regulation Z clearly permits you to order an appraisal at that point.”

Thank you so much again!

[Vcorman]

Mr. R. Cooper,

So, if I understand this correctly, it looks like the mortgage company is not able to get reimbursed for the appraisal fee ONLY in the case if the ITP & the LE was never provided to the borrower even if it’s after the appraisal was ordered? And as long as we paid for the fee upfront and provided the LE/ITP to the borrower(s) after the fact, and the loan has cancelled after all signatures – we should be able to ask for reimbursement, correct?

“Here’s our scenario: The appraisal was ordered 12/5, ITP signed 12/6, but Mortgage Co. paid for it upfront.

So, we can have borrower reimburse us then for the appraisal.”

Can you please also advise if the borrower(S) have to sign the ITP/LE OR just receive it from us… in order for the statement above to be valid.

Thank you so much!!

[Author]

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