01Problem
Origination markups, shrunken lender credits, captive title, and transfer taxes surface on the Loan Estimate and then jump on the Closing Disclosure in the three days before the wire. CFPB 2023 HMDA median purchase total loan costs $6,684; 56.6% of purchase loans paid discount points (median $3,000). Freddie Mac (2023, still cited by CFPB) estimated shoppers save $600–$1,200 per year. TRID (12 CFR 1026.19) is the statute; the buyer has to run the tolerance math.
02Intake
- Same six application items for every lender: name, income, SSN, property address, estimate of value, loan amount sought (12 CFR 1026.2(a)(3)(ii)).
- Every official Loan Estimate PDF (all three pages), every revised LE, the written list of providers, lock-commitment letter, AfBA/Appendix D form.
- Closing Disclosure (all pages) and any “corrected” CD; date, time, and method of receipt.
- Title commitment (Schedules A/B), owner’s and lender’s invoices, simultaneous-issue worksheet.
- Purchase contract: who pays owner’s title, transfer taxes, survey, HOA.
- County/city transfer-tax schedule; HOA estoppel.
- Wiring instructions collected in person at the title office.
03Playbook
- 01
Trigger official LEs, not worksheets. Once the six items are in, each creditor must deliver or mail the LE by the third business day (1026.19(e)(1)(iii)(A)). The creditor shall not require verifying documents as a condition of issuing the LE (1026.19(e)(2)(iii)). Pay only a bona fide credit-report fee (typically <$30) before intent to proceed (1026.19(e)(2)(i)). Worksheets must carry the 12-point top-of-page disclaimer that actual costs could be higher.
- 02
Get at least three LEs the same week, same product, same lock status. CFPB Ask CFPB en-137. Cluster hard pulls in 14 days (covers older FICO and VantageScore; newest FICO uses 45 days). Compare: Rate Lock Yes/No + expiration; note rate; Section A origination including points; lender credits; cannot-shop B vs can-shop C; transfer taxes vs recording; MI/MIP/funding fee; Cash to Close; APR/TIP/In 5 Years; Prepayment Penalty / Balloon.
- 03
Map every fee into a TRID tolerance bucket using unrounded dollars (Comment 19(e)(3)(i)-7).
- Zero tolerance: fees to the creditor, mortgage broker, or an affiliate of either; unaffiliated cannot-shop third-party fees; transfer taxes; shrinkage in lender credits (Comment 19(e)(3)(i)-5). Section A origination lives here.
- 10% cumulative (not line-by-line): recording fees + unaffiliated shoppable services selected from the written list (or not shopped). One line may rise more than 10% if the sum of the bucket stays within 10%.
- Unlimited: prepaid interest; property insurance; initial escrow; off-list providers the consumer chose; property taxes and unrequired third-party services.
- 04
Changed circumstance is a legal reset. Valid reasons (1026.19(e)(3)(iv)): extraordinary event; relied-on information that was inaccurate or changed; new information; eligibility/value change; consumer-requested changes that increase a charge; rate lock (revised LE within 3 business days of lock). CFPB Ask CFPB en-172 examples: different product, down-payment change, appraisal surprise, new credit, overtime that will not document. Revised LE due within 3 business days of information sufficient to establish the reason. No revised LE on or after the CD. Last revised LE must be received at least 4 precise business days before consummation.
- 05
Written list of providers is mandatory when shopping is permitted (1026.19(e)(1)(vi)): at least one available provider per shoppable service, separate from the LE, same timing. Off-list providers move that charge into the unlimited bucket. Affiliate title leaves the 10% bucket and becomes zero-tolerance.
- 06
Points must buy a lower rate. One point = 1% of loan amount, itemized as “__% of Loan Amount (Points)” connected to a discounted rate (1026.37(f)(1)(i); CFPB en-136). A “point” that does not cut the note rate versus that lender’s 0-point LE is an origination fee. Break-even months = points dollars ÷ monthly P&I savings.
- 07
Confirm CD receipt against consummation. Consumer must receive the CD no later than 3 precise business days before consummation (1026.19(f)(1)(ii)(A)). Precise business day = all calendar days except Sundays and 5 U.S.C. 6103(a) holidays; Saturday counts. Mail/email deemed received 3 precise business days later unless earlier-receipt evidence. Purchase-money buyers do not get TILA’s 3-day rescission (1026.23(f)(1)).
- 08
Only three CD changes restart the 3-day wait (1026.19(f)(2)(ii)): (i) APR becomes inaccurate (regular 1/8 of 1 percentage point; irregular 1/4); (ii) loan product change; (iii) prepayment penalty added. Other changes: corrected CD at or before consummation. A rate drop that overstates APR via an overstated finance charge can remain accurate under 1026.22(a)(4).
- 09
Line-by-line LE vs CD audit (the hour the CD arrives). Page 1: loan amount, rate, P&I, prepay/balloon, escrowed monthly, cash to close. Section A: any increase is zero-tolerance unless a documented changed circumstance. Section B cannot-shop: zero if unaffiliated-cannot-shop or affiliate. Section C can-shop: 10% if from the list and unaffiliated; unlimited if off-list; zero if affiliate. Section E: transfer taxes = zero; recording = 10%. Section F prepaids: unlimited. Section G escrow: unlimited, but RESPA cushion cap is 1/6 of annual disbursements (12 CFR 1024.17(c)(1)). Section H: buyer-paid broker compensation when the buyer pays (VA Circular 26-24-14). Lender Credits on the CD must be ≥ LE credits. No CD-preparation fee (1026.19(f)(5)); amount imposed cannot exceed what the provider received (1026.19(f)(3)(i)).
- 10
Cure math. Excess zero- or 10%-bucket charges must be refunded within 60 days after consummation with a corrected CD (1026.19(f)(2)(v)). Commentary example: four zero-tolerance overages $30+$25+$25+$15 ($95) + 10% overage $90 = $185 refund. Demand it in writing the day you see it.
- 11
Shop title; match promulgated rates. Owner’s policy is optional and must be labeled “Title — Owner’s Title Policy (optional)”. Seller cannot require a particular title company (12 U.S.C. § 2608) — treble the title charges. Simultaneous-issue split (Comment 37(g)(4)-2): disclose lender’s at full premium; owner’s = (full owner’s + simultaneous lender) − full lender’s. Example: $2,568 + $200 − $1,175 = $1,593 owner’s disclosed. Texas TDI March 1, 2026: $400,000 → $2,262. Florida r. 69O-186.003: $400,000 = $2,075.
- 12
Wire protocol + 7-day LE wait. Two named contacts, numbers written down in person. If funds moved: wire recall + IC3.gov the same day. FBI IC3 2025: 12,368 real-estate complaints / $275.1 million. Consummation may not occur until the seventh precise business day after the LE is delivered or mailed (1026.19(e)(1)(iii)(B)). 10-business-day LE expiration is a tolerance reset, not a must-sign date.
04Checklists
Closing-cost and Loan Estimate auditor
- Six items submitted to ≥3 lenders; official H-24 LEs dated the same week
- Only a credit-report fee paid before intent to proceed
- Written list of providers in the file
- AfBA form if any affiliate
- 0-point, 1-point, and credit quotes compared; points actually cut the note rate
- CD received ≥3 precise business days before consummation (evidence of receipt)
- LE vs CD zero-tolerance and 10% math on unrounded dollars
- Lender credits on CD ≥ LE credits
- No CD-preparation fee; third-party invoices match amounts charged
- Owner’s title labeled (optional); simultaneous-issue totals foot
- Transfer-tax vs recording-fee buckets correct
- Escrow cushion ≤ 1/6 of annual disbursements
- Wire instructions voice-verified on a pre-existing number
05Questions to ask
- Q01
“Please issue an official Loan Estimate from these six items only — no purchase contract, tax returns, or bank statements (12 CFR 1026.19(e)(2)(iii)).”
- Q02
“Give me three LEs on the same 30-year fixed: 0 points/0 credits, 1.000 point, and a ~$4,000 lender credit, all with Rate Lock labeled.”
- Q03
“Which Section C services may I shop, and where is the written provider list required by 1026.19(e)(1)(vi)?”
- Q04
“Are you requiring affiliated title or escrow? Send the Appendix D AfBA disclosure. I will shop title under 12 U.S.C. § 2608.”
- Q05
“On what date and by what method did I receive this Closing Disclosure, and what evidence of receipt will you produce?”
- Q06
“Produce the LE-to-CD comparison with unrounded dollars, bucketed zero / 10% / unlimited, and refund any excess under 1026.19(f)(2)(v).”
- Q07
“Itemize every Section A fee and the payee. Which are new since the LE, and what changed circumstance supports them?”
- Q08
“Confirm wiring instructions by reading back bank, routing, account name, and account number on the number I collected at the title office. I will ignore email changes.”
06Red flags
LE withheld until a signed contract or tax returns arrive
Card number collected for processing/appraisal before intent to proceed
Discount points that do not cut the note rate vs that lender’s par LE
New origination/processing/underwriting fee in Section A on the CD; lender credits shrunk
Affiliate title without AfBA, or seller-required title company
CD first produced at the table
APR jumped outside 1/8% (regular) without a new 3-day wait
Email changing wiring instructions
Telling a purchase buyer they can rescind in three days
07Scripts
Application for a Loan Estimate under 12 CFR 1026.2(a)(3)(ii) and 1026.19(e). Consumer: [name, SSN, income $X]. Property: [address], estimated value $[Y], loan amount sought $[Z], occupancy primary, 30-year fixed conventional. Please issue official Loan Estimates — not worksheets — for (1) 0 points / 0 credits, (2) 1.000% discount points, (3) approximately $4,000 lender credit. Do not require a purchase agreement or verifying documents. The only fee I authorize before intent to proceed is a bona fide credit-report fee. Include the written list of providers.
Under 12 CFR 1026.19(f)(1)(ii) I must receive this Closing Disclosure at least three precise business days before consummation. I received it on [date] by [email/mail/in person]. Compare to Loan Estimate dated [date], using unrounded dollars:
- Section A origination increased $[X] (zero tolerance, 1026.19(e)(3)(i)).
- Lender Credits fell from $[Y] to $[Z] (Comment 19(e)(3)(i)-5).
- Transfer taxes increased $[A] (zero tolerance).
- Title — Owner’s is not labeled (optional). Demand: a corrected CD, a tolerance refund of $[X + credit shrinkage + A] under 1026.19(f)(2)(v), the provider invoices for credit report and courier, and the Appendix D AfBA disclosure. I will not wire on emailed instructions.
12 U.S.C. § 2608 prohibits requiring, as a condition of sale, that I buy title insurance from a particular company; the remedy is three times the title charges. 12 CFR 1024.15 requires an Appendix D disclosure and that I am free to shop. I am selecting [unaffiliated title company] for owner’s coverage. Please remove the required-use condition and reissue the CD.
08Tools
Callable over MCP once connected. Your agent passes the inputs and gets structured results back.
le_cd_tolerance_engineLE-vs-CD tolerance engine- TRID tolerance test: zero-tolerance increases are refunded dollar for dollar; the 10% bucket is tested in aggregate (recording + unaffiliated services chosen from the written list); a shrinking lender credit counts as a zero-tolerance increase. Returns the cure and the 60-day refund deadline.
title_premium_checkerTitle-premium checker- Computes the promulgated owner's title premium in Texas (TDI formula quoted in the skill, faces $100,000–$1,000,000) or Florida (Fla. Admin. Code R. 69O-186.003, all tiers: $5.75/$5.00/$2.50/$2.25/$2.00 per thousand, reissue $3.30/$3.00/$2.00/$1.50, $100 minimum, any fraction of $100 counted as $100) and compares it with your Closing Disclosure; explains the TRID simultaneous-issue disclosure.
cd_three_day_calendarClosing Disclosure 3-day calendar- Presumed receipt of the Closing Disclosure (in person: same day; mail/email: 3 precise business days later), the earliest consummation date (3 precise business days after receipt), and whether a change restarts the wait (APR increase over 0.125 points, product change, prepayment penalty added).
09Formulas & rules
- PMMS week of Oct. 29, 2026: 30-year 7.24%; 15-year 6.60%.
- Points break-even on $400,000 30-year: 0 points P&I $2,725.99. 1 point ($4,000) at a typical 0.25% cut → 6.99% P&I $2,658.52, save $67.47/month, break-even ≈ 59 months. $4,000 lender credit at +0.25% (7.49%) P&I $2,794.12. (CFPB: the rate cut “depends on the lender.”)
- Zero vs 10% worked: LE shoppable+recording $2,000; CD $2,150 = 7.5% — inside 10%. Section A $1,800 → $1,950 with no changed circumstance = $150 zero-tolerance refund. Lender credits $1,000 → $700 = $300 more. Total $450, due within 60 days.
- Texas owner’s (TDI March 1, 2026): ((Face - 100{,}000) \times 0.00494 + 780). $400,000 → $2,262. Florida r. 69O-186.003: $400,000 → $2,075.
- Prepaid interest: (Loan \times Rate / 365 \times days). $400,000 × 0.0724 / 365 ≈ $79.34/day; close on the 15th of a 31-day month ≈ $1,349. Escrow cushion: taxes $6,000 + HOI $2,508 = $8,508; max cushion $1,418 (1/6).
- APR restart: disclosed APR 7.375%; new 7.51% is 0.135 over — above 0.125 — new 3-day wait. New 7.48% (0.105 over) — no APR restart.
- Philadelphia $400,000: combined RTT 4.578% = $18,312 (city page also shows a 3.278% mail-in figure — confirm at recording). DC cliff: 2.9% on $400,000 = $11,600 vs 2.2% on $399,000 = $8,778.
10State variation
- No adopted TRID amendment as of October 30, 2026. EO 14393 (March 13, 2026) and July 2026 RFI (CFPB-2026-0018) asked about tolerance relief — request, not a rule.
- Texas title −6.2% effective March 1, 2026 (Order 2025-9697).
- EO 14438 (October 22, 2026): FHFA refinance title-acceptance pilot expansion. Purchase files still need lender’s title.
- Homebuyers Privacy Protection Act, Pub. L. 119–36, signed September 5, 2025, effective ~March 4–5, 2026, limits CRA sale of mortgage-inquiry trigger leads.
- NAR (August 17, 2024): buyer-paid broker compensation belongs on CD Section H. NY mansion tax 1% on ≥$1,000,000 (buyer). NJ P.L. 2025, c.69 seller-paid mansion fee for deeds recorded on/after July 10, 2025.
11Community tactics
- Compare official Loan Estimates line by line (Section A, points, cash to close), not worksheets — Verified. 12 CFR 1026.19(e)(2)(ii) and CFPB owning-a-home shopping page.
- Closing-cost threads asking “what’s negotiable” — Partly. Origination/points/credits and shoppable title are negotiable; transfer taxes and recording are government charges; prepaid interest is day-count math. No community dollar “typical credit” is used.
12Fact-check notes
- CFPB Ask CFPB en-172 — works, reviewed September 11, 2024; zero / 10% / unlimited buckets and refund of excess.
- CFPB § 1026.19 — works; timing, tolerances, 60-day cure, no CD-prep fee.
- CFPB TRID FAQs — works; three CD re-disclosure triggers.
- 12 U.S.C. § 2608 — works; treble title charges.
- TDI 2026 rates — works; $400,000 = $2,262.
- CFPB Ask 164 / Ask 1993 — works; owner’s optional; simultaneous-issue usually cheaper.
- NBC, ProPublica, Pennsylvania Insurance Department — not cited in r2 §21.
- Simultaneous lender’s “flat $100 under TDI R-5” — unverified; dropped.
13Tools to implement
Show the tool specifications
- LE-vs-CD tolerance engine. Inputs: LE/CD line items, written-list flag, affiliate flag, changed-circumstance flag. Logic: classify zero / 10% / unlimited; 10% test on the aggregate; credit shrinkage added to zero; output refund and 60-day clock. Data: 12 CFR 1026.19 (https://www.consumerfinance.gov/rules-policy/regulations/1026/19/); Comment 19(e)(3) (https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-19/).
- Title-premium checker. Inputs: state, policy face, simultaneous-issue flag. Logic: apply TDI 2026 formula or Florida 69O-186.003; flag CD vs chart. Data: TDI (https://www.tdi.texas.gov/title/titlerates2026.html).
- CD 3-day calendar. Inputs: send method/datetime, proposed consummation, APR old/new, product-change and prepay-added flags. Logic: precise-business-day receipt (mail +3); restart only on the three triggers. Data: 12 CFR 1026.19(f); CFPB TRID FAQs (https://www.consumerfinance.gov/compliance/compliance-resources/mortgage-resources/tila-respa-integrated-disclosures/tila-respa-integrated-disclosure-faqs/).
14Sources
- 01
- 02
- 03Can my final mortgage costs increase from the Loan Estimate?consumerfinance.gov
CFPB, last reviewed September 11, 2024
- 04
- 05
- 06
- 07
- 08
- 09Fla. Admin. Code R. 69O-186.003 Title Insurance Ratesflrules.org
Florida OIR rule, effective Jan. 27, 2002 (owner's $5.75/$5.00/$2.50/$2.25/$2.00 per thousand; reissue $3.30/$3.00/$2.00/$1.50; $100 minimum)
- 10
Demand evidence r2 F4×P4×S5 = 80; r1/r2 “compare official Loan Estimates line by line, not worksheets” (u/Denjay85) and r/FirstTimeHomeBuyer “Closing costs seem high for $255k home purchase”