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SAMCO’s clients disclose appraisal costs in two different ways on the Good Faith Estimate and initial Truth in Lending Disclosure (both being replaced by the new CFPB Loan Estimate in August 2015).  The first is to total both the appraisal management fee and appraisal fee into one total cost.  The second is to separate and identify the two individual fees to the consumer.  

Do you feel like you’re being buried under not just new regulations, but the paperwork that accompanies it?  When it comes to compliant appraisal policies and procedures many community bank lenders believe they are compliant now, or at the least, believe they know what to do to become compliant.  But so many regulations have changed that touching all the bases can be difficult.  The Consumer Financial Protection Bureau (CFPB) is moving towards enforcement and oversight, and penalties that will make everyone take notice.

One of the many regulations that the CFPB is charged to oversee is the Equal Credit Opportunity Act (ECOA). One existing ECOA appraisal rule is: