Upfront fees not disclosed on GFE

[JM-AM]

The appraisal company will get paid for their services no matter if your loan is approved or denied.

The Lender does not appraise the home. The Lender does not own the Appraisal Company (if they did they would have to disclose it to you in writing).

Being denied because of your credit, or income, or employment, something of that nature will give you the refund.

Being denied funds because appraisal came in lower then selling price, and seller will not lower price, will not give you a refund.

[AtTheRaces]

Thanks JM-AM,

So, two concerns: "Unable to provide a loan approval" and "withdrawing the loan application because we would not provide our credit card information to pay the appraisal and application fees up-front" are both loan denials, yes?

Secondly, if so, doesn't RESPA and other Fed and State consumer laws require that the reasons for "loan withdrawal/denials" be provided?

Again, the "loan withdrawal/denial" reason can't be for non-payment of upfront costs in our case, because Citbank said that these costs were being waived, and because the first and all subsequent GFE's for this particular loan show these fees as being paid for at closing.

What I still see is that the XXXX company says that they can deny your loan for whatever reason(s) (denied due to low apprasial, for example) and still keep the all of money, even the appraisal fee:

"If we are UNABLE TO PROVIDE A LOAN APPROVAL, THE FULL FEE SHALL BE RETAINED BY XXXXXX AND IS NON-REFUNDABLE."

Thanks.