TRID fee tolerance monitoring that catches the cure when the fee changes, not at closing
Tolerance cures prevented when the fee changes, not paid at closing.
See one case, screen by screen ↓Watching every fee between the Loan Estimate and the Closing Disclosure against the TRID tolerance buckets — zero tolerance, 10% cumulative and no tolerance — while the loan is still open. TRID Fee Tolerance Monitoring does it with six agents: they lay every disclosure side by side, tie each fee increase to a valid changed circumstance or flag the cure, and count every disclosure clock.
How to choose AI solutions for lending →
Updated
Fees move between the Loan Estimate and the Closing Disclosure. The lock desk re-prices, an appraisal comes in low, the title commitment shows a PUD, a settlement agent sends a new fee schedule. Each change only resets the baseline if it is a valid changed circumstance and a revised Loan Estimate goes out within three business days of the lender knowing about it.
In many shops nobody checks that until the Closing Disclosure is balanced against the settlement agent’s fee sheet — a few days before a Thursday closing, when it is too late to re-disclose. The changed-circumstance note says “rush appraisal” and nobody asks who wanted the rush. Re-disclosure counts office days; receipt counts every day but Sundays and federal holidays. Miss either clock and the lender pays the difference as a cure.
Estimated split for one loan with a fee change between the Loan Estimate and closing, by hand and with the solution.
Six specialist agents judge every fee change and count every disclosure clock; the disclosure desk approves and sends.
Tuesday 13 October, 8:40 am. Last Thursday the Hensleys’ appraisal came in at $598,000 on a $612,000 purchase, and on Friday the lock desk re-priced the loan. Closing is Thursday 22 October. Here is the day, screen by screen, in the working solution.
Renée’s home screen opens on the work itself: a rail of loans with a fee change — Hensley, Brennan, Okonkwo, Sorensen, Abernathy, Haddad — and the Hensley file laid out as versions. LE 1, LE 2 (the baseline, locked at 6.375%), LE 3 not drafted yet, and CD 1 from Quillfeather’s fee sheet of 12 Oct, every fee a row grouped by tolerance bucket. LE 3 is due at 5:00 pm, 8 h 20 m from now.
“Five fees moved after LE 2. The watcher opened a check when the lock desk re-priced on Fri 9 Oct 10:42. Nothing is judged yet.”
Renée presses “Check CD 1 against the Loan Estimates”. Six agents compare 19 fees across four versions and judge each increase against its evidence. Discount points up $2,448: valid — the appraisal at $598,000 is new information about the property — and reset if LE 3 goes today. Appraisal fee $650 to $825: no changed circumstance, a $175 cure. Title and recording fees run 15.0% over LE 2, past the 10% limit: a $158 cure.
Cure owed if LE 3 goes today: $333.
The processor’s note says “Rush appraisal — borrower closing date”. The judge reads the email behind it: on Fri 2 Oct the loan officer asked the appraisal management company to rush the order “so we don’t run tight on the lock”. Nothing from the Hensleys asks for it. A reason the lender caused is not a changed circumstance, so the appraisal fee stays at its zero-tolerance baseline.
Limit: a reason the lender caused is never valid.
Every change shows when the lender knew, the re-disclosure deadline counted in office days, whether a Loan Estimate followed, and the decision quoted from the file. The appraisal: valid, send today. The rush: not valid. The PUD on the title commitment: valid but too late — the window closed Tue 6 Oct. Quillfeather’s new title fee schedule: not valid, a provider’s price change. Renée accepts or overrides each one.
The judge recommends; the disclosure desk accepts. An override needs a written reason and the compliance officer.
Each fee sits in its bucket against its baseline. Zero tolerance: a $175 cure for the appraisal rush, the points reset by LE 3. The 10% bucket: Loan Estimate total $3,140, limit $3,454, Closing Disclosure $3,612 — 15.0% over, a $158 cure. No tolerance: six fees, insurance, prepaid interest and escrows, in good faith.
A switch on the board — “LE 3 goes today” or “If LE 3 misses 5:00 pm” — recomputes every baseline. Miss the clock and the points cell turns red: LE 3 not sent in three office days, a $2,448 cure. The total owed at closing jumps from $333 to $2,781.
“LE 3 missed · points not reset.”
The loan timeline puts every disclosure, change and clock on one calendar to closing. Re-disclosure counts office days — Mon 12 Oct was Columbus Day, and the office was open. Receipt counts every day but Sundays and federal holidays. The Closing Disclosure must be received by Mon 19 Oct, and LE 3 must be received before the CD goes.
“If LE 3 goes today but is not opened, it is presumed received Fri 16 — and a CD sent then would land Tue 20, a day late. Ask the Hensleys to sign by Wed 14.”
The revised Loan Estimate is drafted on the form, with the changes marked: 0.750% of loan amount in points at $3,672, mortgage insurance at $118 a month, the new appraisal and recording figures. Beside it: the changed circumstance, the re-disclosure deadline, e-delivery with e-consent from 3 Sep, and the date it must be received — Sat 17 Oct.
“LE 3 resets only the points. The appraisal rush and the 10% bucket stay cures — sending it does not change them.”
Renée approves and sends LE 3 by e-delivery. The points are reset and $2,448 is prevented. The Closing Disclosure is planned for Thu 15 Oct and will carry a $333 lender credit in Section J — $175 for the appraisal rush and $158 for the 10% bucket — inside her $500 approval limit, so it needs one approval.
“Approved and sent by Renée Okafor · 9:12 am · $2,448 prevented · CD planned Thu 15 Oct.”
Diane sees cures paid on closed loans and cures prevented while the loan was still open, by month, by fee type and by branch. On the working solution’s sample lender, loans closing with a cure fell from 36.1% in January to June to 10.4% in July to September, with no missed re-disclosure clock since July.
The same loan, seen by the people who carry it from the lock to the closing table — what their week looked like, and what it looks like now.
Six specialist agents judge every fee change and count every disclosure clock; the disclosure desk approves and sends.
Watches fee worksheets, the lock desk, appraisal and title orders, and opens a check minutes after any fee or term changes.
Reads every Loan Estimate, Closing Disclosure and settlement fee sheet and maps each fee to its section and line.
Puts each fee in its tolerance bucket, finds the baseline disclosure for it and computes the exposure and the cure.
Reads each changed-circumstance note and its evidence and decides whether it is a valid reason, re-disclosed in time.
Counts every disclosure deadline under the right day count — office days or receipt days — with holidays, delivery method and receipt.
Drafts the revised Loan Estimate, the corrected Closing Disclosure, the Section J cure and the note to the borrower.
Approves and sends; compliance co-approves overrides. The agents propose; a named person decides.
The disclosure desk can ask in plain words — or tell it what to send. Every answer points to the email, note or rule it rests on.
Why isn’t the rush appraisal a valid changed circumstance?
Because the lender caused it. Kyle Brandt asked Northfold for the rush on Fri 2 Oct “so we don’t run tight on the lock”. The processor’s note says “borrower closing date”, but nothing from the Hensleys asks for it. A reason the lender chose is not one of the changed circumstances in §1026.19(e)(3)(iv), and no Loan Estimate followed by Wed 7 Oct either. The appraisal fee is zero tolerance, so the $175 is a cure.
When must the Hensleys receive the Closing Disclosure?
By Mon 19 Oct — three receipt days before the Thursday closing: Wed 21, Tue 20, Mon 19. Saturday counts; Sunday does not. The catch is LE 3: it must be received before the CD goes. Unopened, LE 3 sent today counts as received Fri 16, and a CD sent then and not opened lands Tue 20 — a day late. Ask them to sign LE 3 by Wed 14 and send the CD Thu 15.
Which loans pay a cure this week if nothing changes?
Five loans: Hensley (points not re-disclosed, the rush and the 10% bucket, $2,781), Brennan (lock extension, LE due today, $373), Abernathy (re-inspection, LE due Thu 15, $150), Haddad (credit re-issue, not valid, $65) and Sorensen (10% bucket at 11.4%, $41). Brennan and Hensley can still be prevented today; the others become cures on the Closing Disclosure.
Send the revised Loan Estimate for the Hensley points change
Sending LE 3 now by e-delivery, approved in your name. It resets the discount points to $3,672 for the appraisal received Thu 8 Oct — inside the three business days, with 7 h 48 m to spare. That prevents $2,448. The appraisal rush ($175) and the 10% bucket ($158) stay cures: $333 in Section J of the Closing Disclosure.
13 screens from the working solution, on its sample data. Pick one to see it large.
Office days, cut-off, alerts and approval limits are settings. The rule’s own day counts are fixed where the regulation fixes them.
| Setting | Default | Choose from |
|---|---|---|
| Office days for sending a revised Loan Estimate | Mon–Fri, open Columbus Day and Veterans Day | Mon–Fri, open Columbus Day and Veterans Day · Mon–Fri, closed on all federal holidays · Mon–Sat |
| Desk cut-off — latest time a disclosure counts as sent that day | 5:00 pm Mountain | 4:00 pm · 5:00 pm · 6:00 pm Mountain |
| Warn before a clock | 1 business day before | 1 business day before · 2 business days before · Same day only |
| Alert when exposure on a loan exceeds | $100 | $0 to $500, in $50 steps |
| Presume receipt when not opened | On — three receipt days after sending | On · Off |
| Borrower chose a provider not on the list | Fees from that provider move to no tolerance | On · Off |
| Disclosure desk approves revised disclosures and cures up to | $500 | $250 · $500 · $1,000 |
| Co-approves overrides and larger cures | Marcus Feld, compliance officer | Marcus Feld · Diane Castellano |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample loan data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (ICE Mortgage Technology study of ~90,000 loans via HousingWire — cures on 35% of loans, $1,225 per loan). Rules cited: 12 CFR §1026.19(e)–(f), §1026.2(a)(6). People, lenders, borrowers and companies named on this page are fictional — characters and sample data in the working solution.
Watching every fee between the Loan Estimate and the Closing Disclosure against the TRID tolerance buckets — zero tolerance, 10% cumulative and no tolerance — while the loan is still open. TRID Fee Tolerance Monitoring does it with six agents: they lay every disclosure side by side, tie each fee increase to a valid changed circumstance or flag the cure, and count every disclosure clock.
The changed-circumstance judge reads the note and the evidence behind it — the appraisal, the lock change, the title commitment, the email — and establishes what changed, when the lender knew and who caused it. It checks the reason against §1026.19(e)(3)(iv) and whether a revised Loan Estimate went within three office days. A reason the lender caused is never valid, and the disclosure desk accepts or overrides every decision.
Under the right day count for each rule. Re-disclosure counts the days your office is open; receipt counts every day except Sundays and federal holidays. It applies your desk cut-off, your holidays, the delivery method and presumed receipt three receipt days after sending when a disclosure is not opened, and warns before each clock — one business day ahead unless you change it.
No. Agents never send a disclosure, move a closing, change a fee or contact a borrower. The redisclosure drafter prepares the revised Loan Estimate, the Section J cure and the borrower note; the disclosure desk approves and sends.
The tolerance calculator works out the cure with its working, and the drafter puts it on the Closing Disclosure as a lender credit in Section J. The disclosure desk approves cures up to its limit — $500 in the sample setup — and the compliance officer co-approves anything larger.
Your Loan Estimates and Closing Disclosures, fee worksheets and settlement agent fee sheets, the lock desk, appraisal and title orders, changed-circumstance notes and email, and disclosure delivery with its opened and signed dates.
Yes. Office days and holidays, the desk cut-off, when to warn before a clock, the exposure alert, the approval limit and who co-approves are settings. Changes are versioned and on the audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your changed-circumstance policy, office calendar, service provider list and a sample of recent loans — and it goes live once every quality gate has passed. We will walk you through it on your own loans first.
An income worksheet in minutes, every figure traced to the return.
1-min demoMortgage Condition ManagementConditions cleared the day the document arrives, not days later.
1-min demoMortgage QC AutomationEvery loan reviewed before it is sold, not a sample after.
1-min demoWe’ll run TRID Fee Tolerance Monitoring on a sample of your own recent loans.