Appraisal Fee Disclosure

Question:

If a customer pays the appraisal fee prior to closing should that fee disclosed as a POC and does it affect TIL?

Answer:

Whether paid at or prior to closing, any fee paid in connection with a RESPA covered transaction must be disclosed on the settlement statement(Appendix A to Part 3500). If paid prior to consummation, the fee is disclosed as POC. Remember to include the name of the service provider. The fee for an appraisal in a real estate transaction, if performed prior to consummation, is not considered a finance charge (2264(c)(7(iv)); therefore, it does not affect the TIL numbers.

First published on BankersOnline.com 2/26/07