| name | trid-tolerance |
| title | TRID Tolerance |
| description | Classifies closing costs into zero, 10% cumulative, and unlimited tolerance buckets under 12 CFR § 1026.19(e)(3). Validates changed circumstances for revised Loan Estimates and computes cure amounts. Use when reviewing a Closing Disclosure against a Loan Estimate, calculating tolerance variances, determining whether a revised LE is permitted, or computing cure amounts for tolerance violations. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/trid-tolerance |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | finance |
| language | en |
TRID Tolerance
Classifies fees into tolerance buckets, calculates CD-vs-LE variances, validates changed circumstances, and computes cure amounts under Regulation Z.
Prerequisites
- Loan Estimate (original + any revised, with dates)
- Closing Disclosure (final or proposed)
- Creditor's written list of service providers (shopped vs. unshopped classification)
- Documentation of any changed circumstances
Tolerance Categories
Zero Tolerance (0%) — Cannot Increase
Any increase requires a valid changed circumstance and revised LE.
| Category | Examples |
|---|
| Creditor/broker fees | Origination, application, underwriting, processing, discount points, commitment, rate lock |
| Affiliate fees | Any fee paid to lender/broker affiliate (title, appraisal, etc.) |
| Transfer taxes | State/local transfer tax, mansion tax, documentary stamps |
| Services borrower cannot shop for | Appraisal (creditor-selected), credit report, flood determination, tax monitoring |
10% Cumulative Tolerance
The aggregate total of all 10% items on CD cannot exceed the aggregate total on LE by more than 10%.
| Category | Examples |
|---|
| Recording fees | Deed recording, mortgage/deed of trust recording |
| Shopped services (from lender's list) | Lender's title, settlement/closing, title search, survey, notary, pest, attorney |
If borrower chose a provider not on lender's written list, that fee shifts to unlimited tolerance.
Unlimited Tolerance
May change freely; original LE must have been made in good faith.
- Prepaid interest, insurance premiums (homeowner's, flood, MI)
- Initial escrow deposits (taxes, insurance, MI, aggregate adjustment)
- Property costs not required by creditor (HOA, assessments, prepaid taxes)
- Services from a provider not on lender's list
- Optional services (home warranty, optional owner's title, elective inspections)
Variance Calculation
Zero Tolerance
For each zero-tolerance fee: Variance = CD Amount − LE Amount
- Compliant: every variance ≤ $0
