You may charge a credit report fee up front, but not application or appraisal fees. Under the TILA-RESPA Integrated Mortgage Disclosure (TRID) rules, a creditor may charge a credit report fee before preparing the Loan Estimate and documenting the consumer’s intent to proceed with the transaction. However, a creditor may not charge other fees, such as application and appraisal fees, until after providing the Loan Estimate and documenting the consumer’s intent to proceed with the transaction.

For resources related to our guidance, please see:

• Regulation Z, Official Interpretations, 12 CFR 1026, Paragraph 19(e)(2)(i)(A), Comment 1 (“A creditor or other person may not impose any fee, such as for an application, appraisal, or underwriting, until the consumer has received the disclosures required by § 1026.19(e)(1)(i) and indicated an intent to proceed with the transaction. The only exception to the fee restriction allows the creditor or other person to impose a bona fide and reasonable fee for obtaining a consumer’s credit report, pursuant to § 1026.19(e)(2)(i)(B).”)

• Regulation Z, Official Interpretations, 12 CFR 1026, Paragraph 19(e)(2)(i)(B), Comment 1 (“A creditor or other person may impose a fee before the consumer receives the required disclosures if the fee is for purchasing a credit report on the consumer. . . . If the criteria in § 1026.19(e)(2)(i)(B) are met, the creditor or other person must accurately describe or refer to this fee, for example, as a ‘credit report fee.’”)