TRID tolerances on a conforming purchase: lender credits, rate locks and the 10% bucket

On a conforming purchase, lender fees and a general lender credit are locked at the Loan Estimate, recording and shoppable fees may rise 10% in aggregate, and a revised LE must follow a rate lock within three business days.

Three buckets, read from a move-up buyer’s Loan Estimate

Zero tolerance covers the origination charges in section A, transfer taxes and any fee paid to the lender’s affiliate or to a provider the lender required you to use. A 10% aggregate bucket covers recording fees and third-party services for which you were allowed to shop but chose a provider from the lender’s list. Everything else — prepaid interest, the initial escrow deposit, homeowner’s insurance and services where you picked your own provider off-list — can change without limit. Move-up buyers who already have a preferred title company fall into that last category by choosing it, which is fine as long as they compared quotes first.

Lender credits are not a moving target

A general lender credit (the negative number in section J) is treated like a zero-tolerance charge: it cannot decrease between the Loan Estimate and the Closing Disclosure unless a valid changed circumstance is documented and a revised LE is issued within three business days. A credit that silently drops from $4,000 to $2,500 because “pricing moved” is a tolerance violation, and the lender must refund the difference at or within 60 days after closing. Specific credits tied to a particular fee are handled the same way. Compare section J line by line, not the total cash to close.

Locking when you are selling and buying in the same week

Floating a rate until the old house closes is tempting on a conforming loan because the lock period is priced. Once you lock, the lender must deliver a revised Loan Estimate no later than three business days after the lock, showing the rate, points and any lock fee; without that revised LE the earlier pricing stands. If the sale slips and the lock expires, the extension cost is a legitimate changed circumstance, but it must appear on a revised disclosure before it shows up on the Closing Disclosure. Ask for the lock confirmation in writing and keep every LE version.

The three-day Closing Disclosure and simultaneous closings

The CD must be received three business days before consummation, and certain changes — an APR move beyond one-eighth of a percent, a switch in loan product, or the addition of a prepayment penalty — restart the clock. A back-to-back sale and purchase leaves no room for a restart, so review the CD the moment it arrives and flag APR differences immediately. Sunday and federal holidays do not count, and “received” is presumed three business days after mailing unless you acknowledge earlier delivery electronically.

What to check

• Check section A and any affiliate or required-provider fee on the CD against the last revised LE — those cannot rise at all.
• Sum the 10% bucket (recording fees plus on-list shoppable services) on both documents; an increase above 10% must be refunded within 60 days.
• A lender credit in section J that decreased without a revised LE is a tolerance violation, not a pricing adjustment.
• Insist on the revised LE within three business days of your rate lock and any lock extension.
• When selling and buying the same week, read the CD on receipt — an APR change above 1/8% restarts the three-day wait.

Frequently asked questions

The lender reduced my credit at closing and said rates changed — is that allowed?

Generally not on its own. A lender credit disclosed on the Loan Estimate may only decrease if a legitimate changed circumstance occurred and a revised Loan Estimate reflecting it was issued within three business days. Absent that paperwork, the shortfall is treated as a tolerance violation and must be refunded. Ask for the revised LE that justified the change.

Which fees on my conforming loan can increase without limit?

Prepaid interest, the initial escrow deposit, property insurance premiums and any service for which you shopped and chose a provider not on the lender’s written list. Those fluctuate with the closing date and your own choices. Lender origination charges, affiliate fees and transfer taxes cannot increase, and the 10% group is limited in aggregate.

The rule in full: TRID: the Loan Estimate and Closing Disclosure. The borrower profile: Conventional loan borrowers. Related guides: Conventional loan requirements: credit, down payment, DTI, reserves, property · Conforming loan limits: how the FHFA number works and what happens above it · Closing costs explained: what is negotiable, what is not · Pre-approval vs pre-qualification: what sellers actually respect.

Other federal rules for conventional loan borrowers

TILA / Reg Z · RESPA · ECOA · Fair Housing Act · HMDA · SAFE Act / NMLS · ATR / QM · HOEPA · HPA / PMI · Servicing rules · FCRA · Flood insurance · MARS rule · SCRA · LO compensation

TRID disclosures for other borrowers

First-time buyers · Veterans · Self-employed · Investors · Retirees · Bad credit · Foreign nationals · Physicians · Heroes · Rural buyers · Condo & second home · Refinancing