Notifying borrower of an increased appraisal fee

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Question:

I am sending a revised Loan Estimate for an appraisal fee increase. What verbiage do I use to justify that the appraisal transfer invoice shows the fee is now $575 versus the $430 which was initially disclosed. This is an appraisal transfer from another lender., and I am not sure what the correct verbiage would be for this change.

Answer:

by Randy Carey:

You need a changed circumstance in order to increase the appraisal fee and I am not sure what that changed circumstance might be in this circumstance. The fact that you disclosed a low amount is not a changed circumstance nor is the fact that you underestimated the price of the appraisal assignment.

Answer:

by John Burnett:

If you are getting the appraisal transferred from another lender, your bank should have nailed down the costs of that transfer in advance of providing the initial loan estimate. Like Randy, I don't see anything in this set of facts that suggests there was a change covered by Regulation Z section 1026.19(e)(3)(iv), paragraphs (A)–(F) that allows you to issue a revised loan estimate and pass an increased cost of the appraisal along to the borrower.