TRID fee tolerances, explained.

TRID fee tolerances for newcomers: why a Loan Estimate binds the lender's closing costs

The life of one purchase loan's disclosures, in five steps

1. Application and the first Loan EstimateThe Hensleys apply on Thursday, Sept. 3. Their first estimate goes out Friday, Sept. 4, with the rate still floating.
2. Rate lock and a revised estimateThey lock at 6.375% on Monday, Sept. 21. The second estimate, with points of $1,224, goes out Wednesday, Sept. 23.
3. Fees move, and each change is judgedA title commitment, a rush appraisal, a low value, a new fee schedule. Each change is valid or invalid, on time or late. This is where the $2,448 is saved or lost.
4. The Closing Disclosure and the three-day waitBuilt from the settlement company's fee sheet; it must reach the Hensleys by Monday, Oct. 19 for a Thursday closing.
5. Closing, the cure and the fileAny excess is credited at closing or refunded within 60 days. The evidence is kept for three years, the Closing Disclosure for five.

Step 3 is the subject of this guide. The lender, borrowers and figures in this example are fictional.

Zero tolerance by default, and three other TRID surprises

Tolerance, changed circumstance, baseline, cure

Fourteen terms are defined in the one-page summary.

Zero, ten percent or unlimited: who is paid and who picked the provider decide a fee's bucket

In shortA fee's bucket depends on who receives it and whether the borrower was allowed to pick the provider, much more than on the fee's name. Lender and affiliate fees, transfer taxes and services the borrower could not shop for are zero tolerance. Recording fees and outside services shopped from the lender's written list share a 10% allowance. Prepaid interest, insurance, escrow deposits and providers the borrower found alone are judged only on whether the estimate used the best information available.

Three details that catch desks out

The CFPB's consumer page gives borrowers the same three lists in plain words: fees that "cannot change at all" unless there is a "change in circumstances", fees that may rise up to 10% in total, and charges that "can increase by any amount at any time".6

The TRID rule since 2015, and the 2026 request that may reopen it

In shortThe tolerance rules live in 12 CFR 1026.19(e) and (f) and their official commentary. They took effect in October 2015 and were last changed in 2017 and 2018. In March 2026 an executive order asked the CFPB to consider replacing TRID's timing rules with a materiality standard, and in July 2026 the CFPB asked the public about timing, tolerances and changed circumstances. Comments closed August 10, 2026. No proposal had been published by the end of October, so every rule in this guide is in force.

What the CFPB asked in July 2026

The six reasons a fee may rise, and the evidence each one needs in the file

In shortA higher fee can replace the old baseline only for one of six listed reasons, and only to the extent that reason caused the increase. A changed circumstance must be specific to this borrower or this loan, or an event outside anyone's control. A reason the lender created on its own, such as a rush it ordered for its own schedule, fails the test. The file has to show what changed, when the lender knew, and who asked.

Three ways a valid reason still fails

How often the loan itself changes before closing

A changed loan-to-value ratio, the case in this guide's example, happened on about a quarter of loans in the CFPB's sample. Each change like it can move pricing, mortgage insurance or program fees, and each one starts a three-day count.17

Events outside anyone's control count too. In May 2020 the CFPB said the COVID-19 pandemic, "as with wars or natural disasters", was "an example of an extraordinary event", and that lenders could use revised estimates "if the COVID-19 pandemic has affected the estimate of such settlement charges".18

Office days and receipt days: counting a TRID deadline the way the rule counts it

In shortSending a revised Loan Estimate counts the days your offices are open for substantially all business. Receiving a revised estimate or a Closing Disclosure counts every day except Sundays and the eleven federal holidays, Saturdays included. A form not handed over in person is presumed received three such days after it is sent, unless you can show it arrived sooner. Getting the calendar wrong in either direction delays a closing or loses a reset.

The Hensley clocks, counted

The last line uses the 60-day refund window: 60 calendar days after Thursday, Oct. 22 is Monday, Dec. 21.3

How the mailbox rule works

A Loan Estimate or Closing Disclosure that is mailed or emailed, instead of handed over, counts as received "three business days after they are delivered or placed in the mail".2 The commentary applies the same presumption to email: sent Monday, "the consumer is considered to have received the disclosure on Thursday, three business days later".3 That presumed date is the latest a lender needs to plan for. Evidence that the borrower received the form sooner, such as an electronic signature, a dated opening record or a hand delivery, sets the actual, earlier date.

Some desks wait until the revised estimate has been received before sending the Closing Disclosure. The rule asks for less: it bars providing a revised estimate on or after the day the Closing Disclosure is provided, and requires the borrower to receive the revised estimate at least four business days before consummation.2,3 Waiting for receipt is a stricter house practice that keeps both conditions safe.

Working out a TRID cure line by line, with the Hensley numbers

In shortPick the right baseline for each fee, then test: zero-tolerance fees one by one, the 10% group as one total against 110% of its baseline total, and the unlimited group for diligence only. Add the excesses, credit them on the Closing Disclosure in Section J with the statement the form requires, or refund them within 60 days of closing.

Step 1: choose each fee's baseline

The baseline is the latest estimate that was allowed to reset that fee. For the Hensleys, the second Loan Estimate reset the points after the rate lock. The rush appraisal never had a valid reason. The settlement company's new fee schedule, a price change across all its customers, is not a fact about this loan.

The title fees are the subtle case. On Thursday, Oct. 1 the title commitment showed the house sits in a planned unit development, a community with shared areas and covenants, which is a valid reason to raise the title endorsements. It added only $150, about 4.8% of the group, and a changed circumstance resets the 10% group only when it lifts the group's total by more than 10%; no revised estimate went out by Tuesday, Oct. 6 in any case. The 10% group keeps its old baseline.3

Step 2: test the zero-tolerance fees one at a time

• Discount points: baseline $1,224 (0.250% of $489,600). If the revised estimate goes today, the new baseline is $3,672 (0.750%) and nothing is owed. If it misses 5:00 p.m., the full $2,448 is owed.
• Appraisal fee: baseline $650, closing $825. Excess $175.
• The other seven zero-tolerance fees did not move.

Step 3: test the 10% group as one total

No single fee is tested on its own here. The recording fee rose 56%, which would be fine if the title fees had come in lower. They did not, so the group is $472 higher, $158 above its limit.

Step 4: total the cure and put it on the form

Sent on time, the revised estimate leaves a cure of $175 + $158 = $333. The Closing Disclosure shows it as a lender credit in Section J, with "a statement that this amount includes a credit for an amount that exceeds the limitations on increases in closing costs", and the cash-to-close table states the excess over "the legal limits".16 If the excess is found after closing, the lender refunds it and sends a corrected Closing Disclosure; Regulation Z allows the refund "no later than 60 days after consummation" (§1026.19(f)(2)(v)).2

Nine loans in ten got a revised disclosure before closing in the CFPB's exam sample

In shortRevisions are the normal case. In the CFPB's exam sample, almost 90% of loans got at least one revised Loan Estimate or corrected Closing Disclosure, about 62% got a revised estimate, and one in five got three or more estimates. Every revision is a judgment and a deadline, which is why disclosure desks exist.

The data are older than anyone would like: loans consummated between March 2016 and November 2017, drawn from examination files.17 No regulator has published a newer count. The same study found the median loan took 44 days from application to closing, and that lenders usually sent the first Closing Disclosure six days before closing, earlier than the rule requires.17

Why lenders pad their estimates

Estimating high protects the lender from a cure and shows the borrower a worse price than the one they will likely pay. The CFPB's data point links the habit to the small decreases in APR it saw between the estimate and closing.17 In the CFPB's lender survey for its TRID assessment, 46.5% of the 99 lenders said that in 2018, when they let consumers shop, they "almost always" gave a written list with only one provider.19

The cost lands on the lender too. Of 89 lenders answering, 87.6% said the number of revised disclosures had raised their ongoing costs, 55.1% significantly; 90.8% of 87 said the same of tolerance violations.19

What bank examiners cite most often: the good-faith estimate rule tops the 2025 list

In shortTruth in Lending is the most cited consumer law in FDIC examinations year after year, and in 2025 the most cited part of it was §1026.19(e), the Loan Estimate and its good-faith rules. The CFPB's examiners have reported fees over tolerance, missing provider lists, missing evidence and rush appraisal fees wrongly blamed on borrowers. We found no public federal or state enforcement action resting on tolerance violations alone between 2024 and 2026; the consequences come through examinations and refunds.

What the examiners wrote

Where tolerance problems come from

Two lessons follow. Arithmetic errors are the easy part: the forms show them. Most of the damage comes from facts the forms do not hold, such as who asked for a rush and on what day the lender knew. And because TRID's deadlines are short, the fact has to be established the day it lands.

Why a missed revision has cost more since 2022: the median points bill more than doubled

In shortDiscount points are paid to the lender, so they are zero tolerance, and they have grown since rates rose in 2022. The median purchase borrower who paid points paid $3,000 in 2023, about two and a half times the $1,225 of 2021. When a valid repricing is re-disclosed late, the whole increase becomes the lender's. One study sponsored by ICE Mortgage Technology, a software vendor, puts cures on 35% of loans; no regulator publishes a rate.

How often lenders pay cures

These are a vendor's figures in a sponsored article, the only published cure rate we found. Read them as a sign of scale, then measure your own: the share of closed loans with a tolerance credit on the Closing Disclosure or a post-closing refund, and the dollars, by fee type.

Defects found after closing

What the CFPB's 2026 questions could change for disclosure desks, and what they cannot change yet

In shortThe CFPB asked whether materiality standards could replace or supplement TRID's timing rules, whether tolerance thresholds should change, and whether to say more about changed circumstances. The questions point at the parts of the work that cost the most. Until a final rule says otherwise, the three-day windows, the receipt rules, the buckets and the 60-day refund all apply, and a lender that relaxes its process early carries the risk.

The executive order behind the request named smaller and community banks, and the CFPB noted that "certain regulations may contribute to higher costs for borrowers", yet most of its questions are open to all lenders.13,12

The same order asked the bank regulators to consider treating good-faith, technical compliance errors "correction-first", with enforcement kept for borrower harm or repeated misconduct; no agency had published such a change for TRID by October 2026.12 Whatever changes, two things carry over: the lender will still have to show why each fee changed, and someone will still count days on some definition.

Software that checks tolerances: what it can decide, what it can only suggest, and which rules govern it

In shortMuch of the work is fixed rules: placing fees in buckets from the provider list, adding the 10% group, counting days on the right calendar. Judging from a note or an email whether a reason is valid, and who caused it, takes judgment: AI can assist, and a person should decide. Bank regulators' 2026 model guidance excludes simple arithmetic and deterministic rules from its definition of a model, and leaves generative AI to each bank's own governance; Fannie Mae and Freddie Mac now require AI governance from the lenders that sell them loans. The lender stays responsible for every disclosure.

What the rule books say about AI

TRID decisions the disclosure desk keeps

• Deciding that a reason is valid, when the evidence is mixed, and accepting the risk of that decision.
• Sending a revised estimate or a Closing Disclosure to a borrower.
• Approving a cure and its amount, and any override of the rules.
• Setting the lender's office calendar, cut-off time and provider list, which every count depends on.
• Keeping the evidence for three years, and the Closing Disclosure for five.15

Software cannot know why a loan officer asked for a rush if nobody wrote it down. It can make sure the question is asked the day the invoice arrives, while there is still time to fix the answer.

Loan officer, lock desk, processor, disclosure specialist, closer: who holds the evidence for a fee change today

In shortA loan officer, a lock desk, a processor, a disclosure specialist, a closer and a settlement company each hold part of the evidence. The disclosure desk owns the forms and the clocks; the closer usually finds the leftover cure when balancing the Closing Disclosure. Most of the hours go to comparing versions and chasing the reason behind each change, and the volume is falling: Fannie Mae's October 2026 forecast, as reported by Scotsman Guide, cut single-family originations to $2.08 trillion for 2026 and $1.86 trillion for 2027, from $2.12 trillion and $2.28 trillion a month earlier.37

Who holds the evidence for a changed closing fee

Four people before a fee change is judged valid

Hours spent comparing fee versions and chasing evidence

Three ways desks do it

Wage benchmark for the people who do much of this work: loan interviewers and clerks, the federal occupation that includes loan processors, had a median wage of $24.05 an hour in 2025.38 With benefits, wages were 70.0% of private employers' compensation costs in June 2026, so a loaded hour is about $34.39

The Hensley re-price: four disclosure versions compared and a revised Loan Estimate sent 7 hours 48 minutes early

In shortThis is the example from the top of the page, inside the product. Six agents compare four versions of the Hensley disclosures, tie each increase to its reason or flag a cure, and count every clock. Renée Okafor, the disclosure desk lead, reads the evidence, approves the revised Loan Estimate at 9:12 a.m. and sends it, seven hours and 48 minutes before the deadline. The borrowers sign it at 10:05.

1

The desk opens on the loan with the nearest clock

Tuesday, Oct. 13, 8:40 a.m. Renée's home screen starts with the loans where a fee changed, ranked by what is at stake: Hensley at the left, with a revised estimate due by 5:00 p.m. Below it, the Hensley file is laid out as versions side by side: the first Loan Estimate, the second (the baseline, locked at 6.375%), a third not yet drafted, and the Closing Disclosure built from the settlement company's fee sheet of Oct. 12.

A lane under the column heads lists what happened before each version: the rate lock, the planned unit development on the title commitment, the title company's new fee schedule, the rush, the appraisal.

2

Every increase tied to its reason, or flagged as a cure

Renée runs the check. Six agents compare 19 fees across four versions in 56 seconds, reading 12 documents. The points rose $2,448 after the appraisal at $598,000, new information about the property, valid if a revised estimate goes today. The appraisal fee rose from $650 to $825 with no valid reason: a $175 cure. The 10% group runs 15.0% over the second estimate: a $158 cure.

The card on the right adds it up: $333 owed if the revised estimate goes today, with 8 hours 20 minutes left.

3

Who asked for the rush

The processor's note says "Rush appraisal, borrower closing date". Renée opens the evidence behind the appraisal chip: an email from the loan officer, Kyle Brandt, to the appraisal management company on Friday, Oct. 2 at 8:52 a.m., asking to rush the order "so we don't run tight on the lock".

Nothing from the Hensleys asks for it. A rush the lender ordered for its own schedule cannot be a changed circumstance, and no revised estimate went out by Wednesday, Oct. 7 in any case. The appraisal fee stays at its $650 baseline.

4

The revised estimate, drafted with the changes marked

The third Loan Estimate is already drafted on the form: points at 0.750% of the loan amount, $3,672; mortgage insurance at $118 a month; the new appraisal and recording figures. Beside it: the reason and the time it was known (the appraisal, Thursday, Oct. 8 at 4:12 p.m.), the deadline, e-delivery with consent on file since Sept. 3, and the date it must be received, Saturday, Oct. 17.

The panel below shows the cure for the Closing Disclosure: $175 plus $158, a $333 lender credit in Section J.

5

Approved, sent and signed

At 9:12 a.m. Renée approves and sends the revised estimate in her own name. The points reset to $3,672, and $2,448 that would have become the lender's cure is prevented. At 10:05 the Hensleys open and e-sign it, so it counts as received today, well before Saturday's deadline, and the Closing Disclosure is planned for Thursday, Oct. 15, a later day than the revised estimate, as the rule requires.

The $333 cure is inside her $500 approval limit, so it needs one approval. Above $500, or for any override, the compliance officer co-approves.

Missed-deadline costs, fee buckets, the clock calendar and cures prevented across a 214-loan pipeline

In shortOne loan is the story. These screens show the rest: what missing the clock would cost, a borrower's own request, the loan's timeline, the whole pipeline, fees by bucket, every changed circumstance, the calendar of clocks, the deadline calculator, cures paid and prevented, the lender's rules, and the confirmation before a send.

Select any screen to open it larger. The lender, borrowers, providers and figures are fictional.

Six tolerance agents watch and count; the disclosure desk approves every revised estimate and cure, compliance co-approves overrides

In shortEach agent has one job and limits it does not cross. None of them sends a disclosure, moves a closing, changes a fee or contacts a borrower. The disclosure desk accepts every decision and approves every revised disclosure and cure up to its limit; the compliance officer co-approves overrides and larger cures. Every change, decision and send is on the record with its time.

Fee change watcher, tolerance calculator and four more TRID agents

People decide; every decision is cited

Approvals record the name, the decision and the time. Agent steps and human decisions are kept apart on the audit trail, and issued disclosures are read, never edited.

The disclosure desk lead and compliance officer in the sample

Every disclosure version, lock event and loan officer email read; a clock timeline, tolerance exposure and a cure ready to approve

In shortIt reads what the loan file already holds, from every disclosure version to the lock desk's events and the loan officer's email, and leaves behind a timeline with every clock, tolerance exposure by bucket, a decision with reasons for every change, and the revised estimate or cure ready to approve. Your loan origination and disclosure systems keep producing and sending the forms.

Systems that hold fees, locks, invoices and delivery times

For each, check whether it has an API, a file feed, or only screens, and who owns it.

Your LOS, disclosure software and lock desk keep their jobs

Three tolerance rules: cite the line, no lender-caused resets, people send

What tolerance cures, late revisions and delayed closings cost a mortgage lender

In shortStart with your own closed loans. The only published cure rate comes from a study sponsored by ICE Mortgage Technology: cures on 35% of loans and $1,225 per loan once staff time is counted. Examiners keep citing the good-faith rule, and discount points, a zero-tolerance charge, have grown since 2022, so one late revision after a repricing can cost thousands. Count the credits on your Closing Disclosures, the refunds after closing and the hours behind both.

Compare a cure with what a loan earns. A lender that earned $785 a loan in production profit in 2025 gives up a large slice of it on any loan that pays a $333 cure, and all of it, three times over, on a loan where a $2,448 points increase was re-disclosed a day late.40

Finding your tolerance cures, refunds and lost resets in a week

Padded estimates, moved closings and other uncounted TRID costs

Resets saved and cures avoided: a TRID monitoring return on your own closings and cure rate

In shortPut in your own numbers. The calculator starts from a published wage and the one published cure rate, and asks you for the rest: closings a year, the share you expect with a cure after monitoring, the average cure and the hours each one costs. Every default marked illustrative is an assumption to replace.

Five sources of TRID savings, from resets to less padding

Your savings on tolerance cures and disclosure desk hours

A lender closing 400 loans a month clears the first two lines. A lender closing 1,000 loans a year with few changes after the lock probably does not on cures alone, and should look at the reset and exam levers before buying anything.

Score your disclosure desk: cure baseline, changed-circumstance policy, calendar cut-off and data access

In shortPick the answer closest to your shop today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score, and each question says why it matters and what a strong answer sounds like.

Your TRID readiness total and the next step it points to

Seventeen checks for tolerance software: bucket placement, baselines, business-day calendars and who sends

In shortAsk every vendor the same questions, us included. The answers show whether the tool judges reasons from evidence or trusts what users typed, counts days on the right calendar, picks the right baseline, and keeps people in charge of what reaches the borrower.

We found no published independent test of any tolerance-monitoring vendor's accuracy, as of October 2026. A back-test on your own closed loans is the fairest comparison, and the same test measures your current process.

Back-test 200 closed loans, then run beside the disclosure desk: a ten-week TRID tolerance trial

In shortMeasure your cures, test on closed loans whose answers you know, then run beside the desk on live loans and decide with three numbers. None of these steps commits you to a vendor.

1. Pull 90 days of closed loans: every Section J tolerance credit and post-closing refund, by fee. That is your baseline.
2. Write down the rules you run on: office days, holidays, cut-off, changed-circumstance policy, approval limits.
3. Back-test on 200 closed loans with known outcomes, including ones with late revised estimates.
4. Run in parallel on the live pipeline for six weeks, with your desk approving every send.
5. Decide with three numbers: cures found before closing, false alarms per hundred loans, desk minutes per changed loan.

Back-test measures: cures found, late clocks, false alarms

Zero tolerance, the 10% group, changed circumstances, the mailbox rule and cure deadlines: TRID answers

In shortThe questions people search most often about tolerances, changed circumstances, deadlines and cures, each answered on its own in a few sentences.