The TRID rule (TILA-RESPA Integrated Disclosure) gives homebuyers federal protection against surprise fee increases at closing. It divides fees into three categories: zero tolerance (fees that cannot increase at all), 10% tolerance (fees that can increase by up to 10% in aggregate), and no tolerance (fees with no cap). If your Closing Disclosure shows increases that violate these rules, your lender may be required to refund the overage.
Zero-tolerance fees are those entirely within the lender's control or where the fee was known precisely at the time of the Loan Estimate. Any increase in these fees between the LE and the CD requires the lender to issue a cure — a refund of the excess — within 3 calendar days of closing.
The 10% tolerance category covers fees for required third-party services where the borrower was permitted to shop but chose a provider from the lender's written list. The aggregate total of all 10%-tolerance fees on the CD cannot exceed the aggregate on the LE by more than 10%.
Individual fees within this group can increase or decrease — what matters is the total. If the combined increase exceeds 10%, the lender must cure the full excess. If you shopped outside the lender's list and chose your own provider, that fee moves to the no-tolerance category.
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Some fees have no tolerance limit because they depend on variables that weren't fixed when the LE was issued. These can change significantly and the lender has no obligation to cure the increase:
Lenders are permitted to issue a revised Loan Estimate if a valid 'changed circumstance' occurs after the original LE. This resets the tolerance baseline to the revised LE. Valid changed circumstances include: acts of God affecting the property, new information discovered after application (e.g., a different loan amount the borrower requested), boundary disputes discovered in title search, and natural disasters.
Changed circumstances do NOT include: the lender finding out information it should have asked for at application, interest rate changes (rate changes don't affect tolerance on fees), or general market changes. If your lender issued a revised LE that you believe was not triggered by a legitimate changed circumstance, you can challenge the revised fee baseline.
If you believe your lender violated TRID tolerances, document the discrepancy in writing and request a cure before closing. If refused, file a complaint with the CFPB.
TRID stands for TILA-RESPA Integrated Disclosure. It is a federal rule that combines mortgage disclosure requirements from two consumer protection laws. Among other things, it sets strict limits on how much closing cost fees can increase between your Loan Estimate and your Closing Disclosure.
Under TRID's zero-tolerance rules, origination charges (origination fees, underwriting fees, application fees, discount points), transfer taxes, and fees for required services where you were not allowed to shop cannot increase between your Loan Estimate and Closing Disclosure. If they do, your lender must refund the difference.
Your lender is required to issue a cure, meaning they must refund you the amount that exceeded the tolerance limit. The cure must be provided no later than the third business day after closing. Request the refund in writing before closing if possible, and document the specific fee amounts from both documents.
Yes, but only if a valid changed circumstance occurred after the original Loan Estimate was issued. Valid reasons include a change in the appraised value, a different loan amount you requested, or a natural disaster. A lender cannot issue a revised LE simply because they made a pricing error or because rates changed.
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