With the new appraisal rules we have started collecting the appraisal fee upfront. We have appraisers on staff and have been told to include the appraisal fee in the origination charge. On the HUD when putting the appraisal fee in line 804 as POC it also puts the fee on the comparison page therefore making us out of tolerance. Since the appraisal fee is in the origination charge on the GFE I can understand why the HUD shows out of tolerance but how are we suppose to disclose the appraisal fee as POC on the HUD?
From RESPA’s FAQs April 2010, p. 49, #8) Q: If the loan originator performs loan origination services typically performed by a third-party for the appraisal, credit report and/or flood certificate, are the charges for these services listed in Lines 804 thru 807 or are the charges included in the loan originator‘s charge in Line 801 on the HUD-1?
A: Charges for the appraisal, credit report and/or flood certificate performed by the loan originator in a transaction must be included in the loan originator‘s charge listed in Line 801 on the HUD-1.