This bill — the Appraisal Reform Act of 2019 — would amend the TILA-RESPA Integrated Disclosure (TRID) rules to require the disclosure of the appraisal management fee separate from the appraisal fee on the Loan Estimate (LE) and Closing Disclosure (CD). This would mean each fee would need to be disclosed separately.
Further, this bill would require the creditor to not charge the consumer more than the amount disclosed on the LE unless there’s a valid “changed circumstance,” defined as:
- An extraordinary event beyond the control of any interested party or other unexpected event specific to the consumer or transaction;
- Information specific to the consumer or transaction that the creditor relied upon when providing the disclosure and that was inaccurate or changed after the disclosures were provided; or
- New information specific to the consumer or transaction that the creditor did not rely when providing the disclosure.
Absent a valid changed circumstance, a creditor wouldn’t be able to adjust the appraisal management fee three days after a mortgage application is provided, even if it determines that additional work is needed.