Closing-table guide
You get your Closing Disclosure at least three business days before closing, and that window exists so you can actually check it. Set the CD next to your most recent Loan Estimate, work down Page 2 first, then run the five-page checklist below. If a lender-controlled fee moved when it should not have, you have language and a template to raise it today.
Every fee on your CD sits in one of three buckets. Which bucket a line belongs to decides whether an increase is normal, negotiable, or something the lender is expected to cure. Page 3 of the CD does part of this comparison for you — but it will not tell you which changes were allowed.
| Bucket | The rule | Typical fees | If the number moved |
|---|---|---|---|
| Zero tolerance | These generally cannot increase from your Loan Estimate at all unless a valid changed circumstance was disclosed to you in a revised Loan Estimate. | Origination charges, points you already locked, the lender's underwriting and processing fees, fees for services you were not allowed to shop for where the lender chose the provider, and transfer taxes. | Any increase without a documented changed circumstance is normally cured by the lender — commonly as a lender credit on Page 2 or 3. Ask for it in writing. |
| 10% cumulative tolerance | This group is measured as a bucket, not line by line. The total of the group can typically rise up to 10% above the Loan Estimate total. | Recording fees, and third-party services you were allowed to shop for where you chose a provider from the lender's written list. | Add the group up on both documents. One line can jump if another falls, but if the bucket total is more than 10% higher, ask the lender to explain or cure the excess. |
| No tolerance limit | These legitimately move because they are market-driven, date-driven, or your own choice — they are not lender pricing. | Prepaid interest (per-diem, tied to your closing date), homeowners insurance premiums, property taxes and escrow deposits, and third-party services you shopped for outside the lender's provider list. | Changes here are usually normal. Still confirm the math: check the number of per-diem days, the insurance premium against your policy, and the escrow months against Page 2's escrow table. |
These generally cannot increase from your Loan Estimate at all unless a valid changed circumstance was disclosed to you in a revised Loan Estimate.
Typical fees: Origination charges, points you already locked, the lender's underwriting and processing fees, fees for services you were not allowed to shop for where the lender chose the provider, and transfer taxes.
If it moved: Any increase without a documented changed circumstance is normally cured by the lender — commonly as a lender credit on Page 2 or 3. Ask for it in writing.
This group is measured as a bucket, not line by line. The total of the group can typically rise up to 10% above the Loan Estimate total.
Typical fees: Recording fees, and third-party services you were allowed to shop for where you chose a provider from the lender's written list.
If it moved: Add the group up on both documents. One line can jump if another falls, but if the bucket total is more than 10% higher, ask the lender to explain or cure the excess.
These legitimately move because they are market-driven, date-driven, or your own choice — they are not lender pricing.
Typical fees: Prepaid interest (per-diem, tied to your closing date), homeowners insurance premiums, property taxes and escrow deposits, and third-party services you shopped for outside the lender's provider list.
If it moved: Changes here are usually normal. Still confirm the math: check the number of per-diem days, the insurance premium against your policy, and the escrow months against Page 2's escrow table.
Section A is what the lender charges to make the loan. Section B is services you were not allowed to shop for. Both are lender-controlled, which is exactly why questionable charges cluster here. Read them together — duplicates often hide across the two.
Section A · Origination charges
Each of these can be legitimate, but stacked together they sometimes double-charge for one workflow. Ask what each one covers that the others do not, and confirm the total matches Section A on your Loan Estimate.
Section A · Discount points
Points appear at the top of Section A as a percentage and a dollar amount. If you locked a par rate, this line should be zero. If it is not, your rate lock and your fees disagree.
Section A · Vague administrative charges
Generic labels are the classic junk-fee shape. Ask for the specific service behind the label. These are lender-controlled and normally sit in zero tolerance.
Section B · Document preparation
Preparing the loan documents is often already inside underwriting or origination. When both appear, ask which one is doing the work.
Section B · Courier, wire, and email fees
Small line items add up, and a delivery fee for documents sent electronically is worth questioning. Ask what was physically couriered.
Section B · Marked-up credit report fee
Third-party pass-through costs should look like pass-through costs. A number several times the market rate usually means a markup, and Section B is not a shoppable bucket.
Sections A & B · Duplicate services
Read the two sections together, not separately. Appraisal review, tax service, and flood certification sometimes appear twice under slightly different wording.
Print this and mark it up with your CD in front of you. Anything you cannot check off becomes a line in the email below.
Page 1
Page 2
Page 3
Page 4
Page 5
Specific beats polite-and-vague. Cite the page, the section, and the line item, then ask a direct question with a deadline tied to your closing date.
Write "Page 2, Section B, line: Document Preparation Fee, $X" rather than "one of the fees looks high." Specific citations get specific answers.
Quote the Loan Estimate amount next to the Closing Disclosure amount and note which tolerance bucket the line belongs to.
Email creates a timestamped record before closing. Copy your real estate agent — agents escalate fee disputes routinely and often know the lender's operations contact.
If a zero-tolerance fee rose with no disclosed changed circumstance, ask specifically for a lender credit on the revised Closing Disclosure rather than a verbal promise to "look into it."
Certain changes — a higher APR beyond tolerance, a switch in loan product, or the addition of a prepayment penalty — restart the three-business-day review period. Most fee corrections do not. Either way, earlier is cheaper.
Subject: Closing Disclosure question — fee discrepancy before signing Hi [Loan Officer], Thanks for sending the Closing Disclosure for [property address], closing [date]. I compared it against my most recent Loan Estimate dated [LE date] and have a few questions before I sign: 1. Page 2, Section [A/B], "[fee name]" — Loan Estimate: $[LE amount]. Closing Disclosure: $[CD amount]. My understanding is this line falls under [zero tolerance / the 10% cumulative bucket]. Can you point me to the changed circumstance and the revised Loan Estimate that disclosed it? 2. Page 2, Section [A/B], "[fee name]" — this appears to overlap with "[other fee name]". Can you confirm what each covers? If any of these increased without a disclosed changed circumstance, please issue a lender credit on a revised Closing Disclosure and send it over. I want to keep our closing date, so an updated CD today would be great. Thanks, [Your name] [Phone]
Expand any term to see what it actually pays for and whether it is lender pricing or a market cost that legitimately moves.
Tolerance categories and the three-business-day rule come from federal mortgage disclosure requirements, but how they apply depends on your loan type, your lender, and whether a changed circumstance was properly disclosed. Fee names vary between lenders and settlement agents. Nothing here determines whether a specific charge on your document is improper.
Educational information only, not legal, tax, or lending advice. Home Approach is not a lender, a settlement agent, or a law firm. Confirm every figure with your lender and settlement agent, and consult a real estate attorney about contract or legal questions.
