Published 2026-05-19
Almost every Closing Disclosure has differences from the original Loan Estimate. Sometimes the changes are legitimate, like a rate lock at a different time, a switch in title companies, or an updated property tax bill. Often they aren't. Federal TRID rules limit how much certain fees can increase between the Loan Estimate and Closing Disclosure. If your lender violated those tolerance rules, they owe you a refund within 60 days of closing. The catch is that you need to identify the problem in the 3-day review window before closing, when corrections are easiest. This guide walks through exactly what to check and what to say.
The Loan Estimate is the lender's best-faith projection of your costs. The Closing Disclosure is the final settlement statement. By federal law, you receive the Closing Disclosure 3 business days before closing.
In between those two documents, several things change for legitimate reasons. Your property taxes get verified by the title company instead of estimated. Your homeowner's insurance gets confirmed by the actual policy you bought. Your appraisal might come in different than expected, triggering different escrow requirements. You might have changed loan products or locked your rate at a different time than originally planned.
What's not supposed to change without notice: the lender's own fees, the third-party fees you didn't shop for, and the title-related costs when you used the lender's recommended provider. These are governed by TRID tolerance rules that the lender is legally required to follow.
If your total closing costs on the Closing Disclosure are more than the Loan Estimate total, your first job is to figure out which specific fees changed and whether the changes are allowed.
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TRID divides every fee into one of three tolerance buckets. The bucket determines how much that specific fee is allowed to increase between the Loan Estimate and Closing Disclosure.
Zero tolerance: fees in this bucket cannot increase at all. Any increase is a TRID violation and the lender owes you a refund.
10% tolerance: fees in this category can increase, but the total of all 10%-bucket fees can only go up by 10% in aggregate. Individual fees can increase by more than 10% as long as the total stays within the cap.
Unlimited tolerance: fees in this bucket can change for any reason. These are services you shopped yourself, prepaid items like interest and insurance, and items that depend on closing timing.
Knowing the bucket each fee falls into tells you whether an increase is a violation or just normal variability.
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The zero tolerance category is where most TRID violations happen, because lenders sometimes quietly increase their own fees and hope the borrower won't notice. The fees in this bucket are: origination fees from the lender, discount points (if you chose to pay them on the Loan Estimate), processing fees from the lender, underwriting fees from the lender, application fees, rate lock extension fees you didn't initiate, and transfer taxes set by state or local government.
If any of these are higher on your Closing Disclosure than on your most recent Loan Estimate, the lender has to refund the difference. The refund must be paid within 60 days of closing. You don't have to file a lawsuit. You just have to point out the violation in writing.
There's one important exception. The lender can issue a "revised Loan Estimate" if a "changed circumstance" justifies the increase. Changed circumstances include things like new information about your credit, a change in the loan you requested, or a change required by law. If the lender issued a revised Loan Estimate before the Closing Disclosure and you received it, the revised version becomes the new baseline. If you never received a revised Loan Estimate, the original one still applies.
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The 10% tolerance category is for fees that the lender estimates but doesn't fully control. These include: recording fees set by your county, third-party services you didn't shop (pest inspection, survey, structural inspection), and title-related services when you used the lender's recommended provider.
These fees can go up, but only by 10% in aggregate. If the total of all your 10%-bucket fees on the Closing Disclosure is more than 10% above the total on the Loan Estimate, the lender has to refund the excess.
Worked example: your Loan Estimate showed $500 in recording fees and $400 in a survey, totaling $900. The Closing Disclosure shows $580 in recording fees and $450 in the survey, totaling $1,030. The increase is $130, or 14.4%. The lender owes you $40 (the amount above 10%, which would have allowed an increase to $990).
The aggregation matters. Individual fees can go up by more than 10% as long as the total stays within 10%. A $50 recording fee that becomes $100 (a 100% increase) is fine if another fee in the same bucket came in $50 below estimate.
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Fees in the unlimited tolerance category can change freely, but you should still understand why they changed. These include: title insurance and title services if you shopped on your own, homeowner's insurance premium, property taxes, prepaid interest, initial escrow deposit, and optional services you elected to add.
Big increases in these categories aren't violations, but they're worth investigating. If your prepaid interest jumped significantly, your closing date moved. If your initial escrow deposit jumped, your tax bill came in higher than estimated. If your title services jumped after you shopped, the title company you ultimately chose was different from what you originally quoted.
Ask the lender or settlement agent to explain any unlimited-tolerance fee that increased by more than 25%. There's usually a logical explanation. Once in a while there isn't, and the increase turns out to be a billing error you can fix.
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Open your most recent Loan Estimate (sent within 3 business days of any major change) and your Closing Disclosure side by side. Both have the same page layout. Compare these specific lines.
Page 1, Loan Terms section: confirm the loan amount, interest rate, monthly payment, and prepayment penalty match. Any changes here should have been communicated to you.
Page 2, Section A (Origination Charges): these are zero tolerance. Compare line by line. The total in section A should be the same or lower on the Closing Disclosure.
Page 2, Section B (Services You Cannot Shop For): these are 10% tolerance in aggregate. Compare totals.
Page 2, Section C (Services You Can Shop For): these are unlimited tolerance if you actually shopped, or 10% tolerance if you used the lender's recommendation. Compare totals.
Page 2, Sections E and F (Taxes, Prepaids, Initial Escrow): unlimited tolerance. Compare totals and ask about any large increases.
Page 3, Calculating Cash to Close section: this shows whether you owe more or less than the Loan Estimate projected. If you owe more and you don't understand why, that's the conversation to have with the lender.
Total time: about 10 minutes if you stay focused. The lender's settlement agent should be willing to walk through any line you don't understand.
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If you identify a zero-tolerance violation (origination, points, processing, underwriting, or transfer tax higher than the Loan Estimate without a revised LE), email the loan officer and copy the closing agent. Use this language:
"I've reviewed my Closing Disclosure against the Loan Estimate dated [date]. The [specific fee] on my Closing Disclosure is $[amount], which is $[difference] higher than the Loan Estimate. This fee is in the zero tolerance category under TRID. I did not receive a revised Loan Estimate with a changed circumstance disclosure. Please confirm that this difference will be corrected before closing or refunded within 60 days as required by 12 CFR 1026.19(f)(2)(v)."
That language usually gets a fast response. The lender knows you understand the rules. In most cases they'll correct the fee before closing rather than process a refund afterward.
For 10%-tolerance violations, use the same approach with the aggregated total: "The total of my Section B fees on the Closing Disclosure is $[amount], which is [X]% higher than the Loan Estimate total of $[amount]. This exceeds the 10% aggregate tolerance under TRID. Please confirm the refund of $[excess amount]."
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"That's just an estimate, the actual cost was higher." This excuse only works for unlimited tolerance items. For zero tolerance items, the estimate was a binding maximum unless a revised Loan Estimate was issued. Push back.
"We sent you a revised Loan Estimate. It's on the portal." Check the portal. If a revised Loan Estimate exists, look at the date. It has to have been provided to you at least 3 business days before the Closing Disclosure to apply. If the dates don't work, the original Loan Estimate still controls.
"The increase is due to a changed circumstance." Ask which changed circumstance specifically. The lender must document this in writing on the revised Loan Estimate. Vague answers like "the loan changed" aren't sufficient. Qualifying changes include: information you provided turned out to be inaccurate, a new requirement was imposed by law or investor guidelines, or your loan terms or property changed materially.
"You'll get the refund within 60 days." This is technically fine if it's a small amount and you trust the lender. For larger refunds, push to have the fee corrected before closing instead. Once you've signed and funds are dispersed, getting money back requires the lender to actually follow through. They usually do, but the friction increases.
"We can't change the fees this close to closing." This is false. Lenders can issue corrected Closing Disclosures up to and at closing. The 3-day review window only restarts if certain core terms change (APR, loan product, addition of a prepayment penalty). A fee correction doesn't trigger a new 3-day waiting period.
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It depends on the fee. Lender fees and transfer taxes can't increase at all (zero tolerance). Recording fees and other lender-recommended third-party services can increase by 10% in aggregate. Fees you shopped yourself or items dependent on timing can change freely.
Under TRID, fees in the 10% tolerance bucket can increase by up to 10% in total between the Loan Estimate and Closing Disclosure. The 10% applies to the sum of all fees in the bucket, not to each fee individually. If the total goes up by more than 10%, the lender has to refund the difference within 60 days.
Generally no, unless a changed circumstance occurred and the lender issued a revised Loan Estimate at least 3 business days before the Closing Disclosure. Fees that appear on the Closing Disclosure for the first time without a revised Loan Estimate are violations and must be refunded.
The lender is required to refund TRID tolerance violations within 60 days of closing whether you ask or not. You can also file a complaint with the CFPB up to 3 years after closing. The practical window is the 3 business days between receiving the Closing Disclosure and closing, when corrections are easiest.
The lender must refund the excess charges within 60 days. If they don't, you can file a complaint with the CFPB at consumerfinance.gov/complaint, report the violation to your state regulator, or sue under the federal Real Estate Settlement Procedures Act. In practice, lenders almost always correct the violation once it's identified in writing.
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