Last reviewed: 16 September 2026
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TRID's tolerance categories and cure requirement, explained
Our TRID timeline explainer covers when the Loan Estimate and Closing Disclosure have to arrive. This is a different, equally federal question about the same two documents: once a fee shows up on your Loan Estimate, how much is it actually allowed to increase by the time you see it again on the Closing Disclosure — and what happens if it increases by more than that.
Not one rule — three separate tolerance categories
Regulation Z, at 12 CFR § 1026.19(e)(3), sorts every fee on a Loan Estimate into one of three buckets, each with a different rule for how much it can grow:
- Zero tolerance. Can't increase at all, for any reason, without triggering a cure. This covers the lender's own origination charges, fees paid to a company affiliated with the lender, transfer taxes, and fees for a required third-party service where the lender didn't let you pick the provider.
- 10% cumulative tolerance. Individual line items in this bucket can move around, but added together they can't grow by more than 10% from the Loan Estimate's total for the group. This covers recording fees and fees for third-party services required by the lender where you picked a provider from the lender's own written list.
- No tolerance limit. Genuinely variable, consumer-driven, or market-set costs — prepaid interest, homeowner's insurance premiums, initial escrow deposits, and fees for a third-party service you selected yourself, off the lender's list — can change without a tolerance cap at all, since they were never a fixed estimate to begin with.
The cure: a refund, not just a corrected form
If the amount actually charged for a zero-tolerance or 10%-bucket item exceeds what the tolerance allows, 12 CFR § 1026.19(f)(2)(v) requires the creditor to refund the excess to the consumer — and the creditor is only treated as compliant if that refund happens no later than 60 calendar days after consummation, generally delivered along with a corrected Closing Disclosure that reflects it. This is a real, dated compliance deadline, not a courtesy: a tolerance violation that's never actually refunded within that window is a real, checkable gap between what Regulation Z requires and what happened.
What this looks like as an actual borrower
Line up your Loan Estimate and your final Closing Disclosure side by side. A zero-tolerance fee — an origination charge, an affiliate fee, a transfer tax — that's higher on the Closing Disclosure than it was on the Loan Estimate is worth asking about directly, and so is a 10%-bucket group of fees that grew by more than 10% in total. A legitimate, documented "changed circumstance" (see our TRID timeline explainer for what qualifies) can reset the baseline the tolerance is measured against — but that's a specific, defined exception, not a blanket excuse for any increase.