Closing Disclosure vs. Loan Estimate: How to Compare Them

Your Closing Disclosure must match your Loan Estimate within strict federal TRID tolerance limits. Some fees can't increase at all. Others can rise by no more than 10%. If your lender exceeded those limits, they may owe you a refund. This guide explains exactly how to compare these two documents line by line and what to do when numbers don't match.

Key differences between the Loan Estimate and Closing Disclosure

The Loan Estimate (LE) is a 3-page document your lender provides within 3 business days of your mortgage application. It shows estimated loan terms and projected closing costs. The Closing Disclosure (CD) is the 5-page final version you receive at least 3 business days before closing, reflecting actual costs.

The LE uses the same general format as the CD, which makes comparison straightforward — but the page numbering differs. Page 2 of your LE corresponds to Page 2 of your CD for closing cost line items. The loan terms summary on Page 1 of each document should be compared carefully, especially the interest rate, monthly payment, and whether your rate is fixed or adjustable.

Zero-tolerance fees: these cannot increase at all

TRID's zero-tolerance category covers fees that were known at the time of the Loan Estimate and are entirely within the lender's control. If any of these increased between your LE and CD, your lender is required to refund the difference — this is called a 'cure.'

  • Origination charges (any fee the lender imposes for making the loan)
  • Points (discount points and origination points)
  • Transfer taxes
  • Fees for required third-party services where you were not allowed to shop (Section B on Page 2)
  • Lender credits — if the credit decreased, that counts as a cost increase

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10% tolerance fees: limited aggregate increase allowed

This category covers fees for third-party services where you were permitted to shop but chose a provider from the lender's list. The total of all 10%-tolerance fees on the CD cannot exceed the total on the LE by more than 10%.

Individual fees within this group can change — but if the combined increase exceeds 10%, the lender must cure the overage within 3 calendar days of closing. Common fees in this category include recording fees, title services (when you used the lender's recommended provider), and required pest inspections.

What to do when fees increased beyond tolerance

First, document the discrepancy in writing. Compare the specific line items on Page 2 of both documents and calculate the overage. Then email your loan officer with the specific fee names, the LE amount, the CD amount, and a request for a cure before closing.

If the lender disputes the violation, request their written explanation. Most lenders resolve legitimate TRID violations quickly — they carry regulatory risk for violations that go uncured. If the lender refuses, you can file a complaint with the CFPB at consumerfinance.gov/complaint or contact your state's banking regulator.

Don't delay closing over small disputed amounts if you have a rate lock expiring. Request the cure, document the lender's response, and you can pursue a refund after closing if needed.

Related fee benchmarks

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