Compliance Memo C2021-05 Valid COC for Appraisal Fee Increases
This memo is notification of updated policies and procedures regarding approvable change of circumstances directly associated with an increase in appraisal fees.
Due to the current market conditions and within certain geographical locations, the ability to obtain an appraisal within the “normal” turn times is becoming a challenge. Every lender and AMC are struggling with the current conditions. To ease the burden on the branches, we have added the following option as an approvable change of circumstance to compliantly increase the consumer’s appraisal fee.
If the consumer is provided several options for the delivery time and cost of an appraisal, and the consumer choses an option that increases the cost of an appraisal (by paying a rush fee) over and above the standard quoted appraisal fee, we will accept this as an approvable change of circumstance subject to the following requirements.
If the consumer chooses an option that increases the cost of an appraisal by paying a rush fee, to be eligible for a valid change of circumstance, we will need documentation which supports that the options were provided to the consumer by the AMC and a response from the consumer stating which option they have chosen. This can be in the form of an email. The option must be chosen by the consumer; it cannot be a decision made by the branch or Loan Officer. The increase in the appraisal cost must be redisclosed within 3 days of notification from the consumer. Any change of circumstance submitted after 3 days from notification from the consumer will be denied and the increase in the cost of the appraisal will be borne by the Branch, no exceptions.
If you have any question or need further clarification, please reach out to the me directly at firstname.lastname@example.org.