Can anyone tell me why a fee charged to the borrower to rush the appraisal is considered a finance charge? The loan application was taken a few weeks prior to closing date. The lender requested the appraiser rush the report. A fee was charge for both the appraisal and to rush the appraisal. QC is including the appraisal rush fee as a finance charge. Is this correct?

They are probably not treating it as a fee for the actual appraisal and playing it safe.

Thank you. QC is stating the lender needs to provide a cure to the borrower for the dollar amount of the fee. The finance charge is over the rush fee. Is there any rebuttal that we can provide?

Internal QC or an investor. If an investor, well good luck. But here is the citation that you would use. I would be asking was the fee not for the appraisal (appraisal fees to assess the value or condition of the property)? If the borrower needed a rapid closing and the appraisal cost was more expensive due to that request, it is still a fee to have the appraisal performed, is it not?

1026.4(c)(7) Real-estate related fees. The following fees in a transaction secured by real property or in a residential mortgage transaction, if the fees are bona fide and reasonable in amount:

(iv) Property appraisal fees or fees for inspections to assess the value or condition of the property if the service is performed prior to closing, including fees related to pest-infestation or flood-hazard determinations.

Thank you! Appreciate this.