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Check a Closing Disclosure

Federal rules limit how much closing costs can rise from the Loan Estimate to the Closing Disclosure. Some charges can’t go up at all, some can go up 10% in total, and some have no limit (§1026.19(e)(3) (opens in a new tab)). Type the amounts from both documents to see whether any charge is above its limit, and by how much.

The lender has to make sure you get the Closing Disclosure at least 3 business days before closing (§1026.19(f)(1)(ii)(A) (opens in a new tab)), so there’s time to check it. Use the first Loan Estimate’s amounts unless a revised one changed them for a reason the rule allows (see “Which Loan Estimate to compare” below). Nothing you type is saved or sent.

This compares the documents you entered. It’s general information, not legal advice or an official Loan Estimate.
A. Origination charges
Can’t go up

Points and the lender’s own fees. Enter each charge on its own line: each is checked on its own, so one that went down doesn’t make up for one that went up.

B. Services you cannot shop for
Can’t go up

Only charges that were in section B on the Loan Estimate. The Closing Disclosure’s section B can also list services from the lender’s list; enter those under C.

C. Services you can shop for
Depends on the provider

The limit depends on who you used. On the Closing Disclosure, providers from the lender’s list appear in section B (“Did Not Shop For”) and ones you found yourself in section C (“Did Shop For”).

  • Limit: Up to 10% in total

Then services you shopped for yourself count in the 10% group (comment 19(e)(3)(iii)-2 (opens in a new tab)).

E to H. Taxes, prepaids, escrow and other costs

E. Recording fees Up to 10% in total

First line of section E. The Loan Estimate adds other government fees that aren’t transfer taxes to it (comment 37(g)(1)-2 (opens in a new tab)); if you know that part, enter it on the next line instead.

E. Other government fees Can’t go up

Only recording fees may rise 10% in total (comment 19(e)(3)(ii)-1 (opens in a new tab)); other government fees on that line can’t go up at all (§1026.19(e)(3)(i) (opens in a new tab)). Blank if none.

E. Transfer taxes Can’t go up

Second line of section E: the part you pay.

F. Mortgage insurance premium Can’t go up

Its line in section F, if any. Mortgage insurance paid into escrow is part of section G.

F. The rest of section F No federal limit

Homeowner’s insurance, prepaid interest and property taxes.

G. Initial escrow payment at closing No federal limit

Section G total.

H. Other No federal limit

Section H total: costs the lender doesn’t require, such as owner’s title insurance.

J. Lender credits
Can’t go down

A smaller credit counts as a higher charge (comment 19(e)(3)(i)-5 (opens in a new tab)). On the Closing Disclosure, add what the lender paid toward specific charges: they’re in the Paid by Others column, where the form may mark them “(L)” (comment 19(e)(3)(i)-6 (opens in a new tab); comment 38(f)-1 (opens in a new tab)). Leave out any credit for an increase above the legal limit, and enter it below instead.

Section J of the Closing Disclosure says when its lender credits include one, and how much. Blank if none.

Result

Type amounts from both documents to see the check.

This compares the documents you entered. It’s general information, not legal advice or an official Loan Estimate.

The three limits

Can’t go up (§1026.19(e)(3)(i) (opens in a new tab); comment 19(e)(3)(i)-1 (opens in a new tab)):

  • Charges paid to the lender or a mortgage broker: section A, points included.
  • Services you couldn’t shop for (section B), and any service from the lender or a company affiliated with it.
  • Transfer taxes.
  • Lender credits can’t go down: a smaller credit counts as a higher charge (comment 19(e)(3)(i)-5 (opens in a new tab)).
  • A mortgage insurance premium paid at closing outside escrow: the list of charges that may change doesn’t include it (§1026.19(e)(3)(iii) (opens in a new tab)).

Each of these is checked on its own: a charge that went down doesn’t make up for one that went up (comment 19(f)(2)(v)-1 (opens in a new tab); comment 38(i)(1)(iii)(A)-2 (opens in a new tab)).

Up to 10% in total (§1026.19(e)(3)(ii) (opens in a new tab)):

The limit applies to the total: one charge can rise more than 10% if the group stays within 10%, and a charge added at closing counts in the total (comment 19(e)(3)(ii)-2 (opens in a new tab)). A service that wasn’t provided comes out of the Loan Estimate total (comment 19(e)(3)(ii)-5 (opens in a new tab)).

No federal limit (§1026.19(e)(3)(iii) (opens in a new tab)):

  • Prepaid interest, homeowner’s and other property insurance, and property taxes.
  • The initial deposit into an escrow account.
  • Services you shopped for with a provider not on the lender’s list; the Closing Disclosure shows them in section C, “Services Borrower Did Shop For” (§1026.38(f)(3) (opens in a new tab)).
  • Services the lender doesn’t require, such as owner’s title insurance or an inspection you chose.

The lender’s estimates of these still had to use the best information it reasonably had. One that was left out, or unreasonably low, can be held to the no-increase rule (comment 19(e)(3)(iii)-2 (opens in a new tab) and comment 19(e)(3)(iii)-3 (opens in a new tab)). This tool can’t judge that: ask the lender if one of these rose a lot.

Which Loan Estimate to compare

Start from the first Loan Estimate. A revised one replaces its amounts only for charges that went up because of one of these reasons (§1026.19(e)(3)(iv) (opens in a new tab)):

  • A changed circumstance: an unexpected event, or information about you or the home that was wrong, changed, or new to the lender.
  • A change you asked for.
  • The rate was locked after the Loan Estimate, which can change the points and lender credits.
  • You said you’d go ahead more than 10 business days after you got the Loan Estimate.
  • New construction expected to close more than 60 days after the first Loan Estimate, if that estimate said it could be revised.

Even then, a charge can only go up by as much as that reason raised it (comment 19(e)(3)(iv)-2 (opens in a new tab)). The lender must send the revised estimate within 3 business days of learning the reason, and you must get it at least 4 business days before closing (§1026.19(e)(4) (opens in a new tab)). If you’re not sure a revision counts, run the check both ways and ask the lender what changed.

If a charge is above its limit

The lender fixes it with a refund of the excess, no later than 60 days after consummation, and a corrected Closing Disclosure (§1026.19(f)(2)(v) (opens in a new tab)). Consummation is when you become bound on the loan (§1026.2(a)(13) (opens in a new tab)), usually the day you sign. A lender can also credit the excess at closing; section J of the Closing Disclosure then says so (§1026.38(h)(3) (opens in a new tab)).

The CFPB’s advice for the days before closing: “If something looks different from what you expected, ask why” (Closing Disclosure Explainer (opens in a new tab)). If a question isn’t resolved, you can submit a complaint to the CFPB (opens in a new tab). A HUD-approved housing counselor can go through the documents with you, often at little or no cost (Find a housing counselor (opens in a new tab)).

Sources

Checked on September 27, 2026 against the regulation, 12 CFR 1026.19 (opens in a new tab) (eCFR), and its official interpretations (Supplement I to Part 1026, on the CFPB’s site), with the forms’ contents in §1026.37 (opens in a new tab) and §1026.38 (opens in a new tab). Comparing loans before you pick one? Compare loan offers.