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name: trid-tolerance language: en description: Classifies closing costs into zero, 10% cumulative, and unlimited tolerance buckets under 12 CFR § 1026.19(e)(3). Validates changed circumstances for revised Loan Estimates and computes cure amounts. Use when reviewing a Closing Disclosure against a Loan Estimate, calculating tolerance variances, determining whether a revised LE is permitted, or computing cure amounts for tolerance violations.

TRID Tolerance

Classifies fees into tolerance buckets, calculates CD-vs-LE variances, validates changed circumstances, and computes cure amounts under Regulation Z.

Prerequisites

1. Loan Estimate (original + any revised, with dates)
2. Closing Disclosure (final or proposed)
3. Creditor's written list of service providers (shopped vs. unshopped classification)
4. Documentation of any changed circumstances

Tolerance Categories

Zero Tolerance (0%) — Cannot Increase

Any increase requires a valid changed circumstance and revised LE.

Category	Examples
Creditor/broker fees	Origination, application, underwriting, processing, discount points, commitment, rate lock
Affiliate fees	Any fee paid to lender/broker affiliate (title, appraisal, etc.)
Transfer taxes	State/local transfer tax, mansion tax, documentary stamps
Services borrower cannot shop for	Appraisal (creditor-selected), credit report, flood determination, tax monitoring

10% Cumulative Tolerance

The aggregate total of all 10% items on CD cannot exceed the aggregate total on LE by more than 10%.

Category	Examples
Recording fees	Deed recording, mortgage/deed of trust recording
Shopped services (from lender's list)	Lender's title, settlement/closing, title search, survey, notary, pest, attorney

If borrower chose a provider not on lender's written list, that fee shifts to unlimited tolerance.

Unlimited Tolerance

May change freely; original LE must have been made in good faith.

• Prepaid interest, insurance premiums (homeowner's, flood, MI)
• Initial escrow deposits (taxes, insurance, MI, aggregate adjustment)
• Property costs not required by creditor (HOA, assessments, prepaid taxes)
• Services from a provider not on lender's list
• Optional services (home warranty, optional owner's title, elective inspections)

Variance Calculation

Zero Tolerance

For each zero-tolerance fee: Variance = CD Amount − LE Amount

• Compliant: every variance ≤ $0
• Violation: any positive variance is the cure amount for that fee

10% Cumulative Tolerance