On September 1^st we began our discussion related to disclosure of the property appraisal fee on the Loan Estimate. Remember that after October 3^rd the Integrated Disclosure Rule (“TRID”) provides that the appraisal fee is subject to a zero tolerance threshold.

In the previous installment of this blog post we discussed the challenge presented to your credit union by moving the appraisal fee from the 10% tolerance category (where it is currently) to the zero tolerance category. In addition, we talked about some proactive steps your cooperative can take after October 3^rd to protect against unexpected increases in the appraisal fee. Today, I’d like to review the concept of “changed circumstances” and how the occurrence of a valid changed circumstance may allow your institution to increase the appraisal fee before closing.

Understanding Changed Circumstances

So you were proactive (or at least you thought) in trying to pin down an accurate appraisal fee; however, it ended up still costing more than you disclosed on the Loan Estimate. Does your credit union just have to eat the additional expense?

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