How to compare your Closing Disclosure to the Loan Estimate
Compare your Closing Disclosure to your most recent Loan Estimate and check your rate, APR, loan amount, payment, closing cash and each fee. Lender fees generally can't rise, some third-party fees can rise 10% as a group, and others have no cap. You get three business days to review.
Closing Disclosure vs Loan Estimate: what each form is
The Closing Disclosure is the final version of your loan's terms and costs. The Loan Estimate was the lender's early quote. Federal rules sort fees into groups, and each group has its own limit on how far the final number can move.
Use your most recent Loan Estimate, since a lender can revise it when something legitimately changes. CFPB suggests starting with the table at the top of page 3 of the Closing Disclosure.
Reverse mortgages, home equity lines of credit, certain subordinate homebuyer assistance loans and manufactured home loans not secured by real estate don't use these forms.
How the Closing Disclosure three day rule works
By law the form must reach you at least three business days before closing. Review it the day it arrives, while errors are easier to fix.
A corrected form can restart that three-day wait, but only in three cases:
- The APR becomes inaccurate under federal rules.
- The loan product changes.
- A prepayment penalty is added.
Any other change only needs a corrected form by closing, so a late fee change won't delay your date. An APR overstated because your rate went down doesn't trigger a new wait either.
Can closing costs change? Limits by fee group
| Fee group | What's in it | How much it can rise |
|---|---|---|
| No increase | Fees paid to the lender, a mortgage broker or their affiliates; third-party services you weren't allowed to shop for; transfer taxes | Zero, unless a valid change allows it |
| 10% as a group | Recording fees and third-party services you could shop for, when you used a provider from the lender's list | The group's total can't exceed the estimate's total by more than 10% |
| No set limit | Prepaid interest, homeowners insurance premiums, escrow deposits, property taxes, services the lender doesn't require, and providers you chose yourself from outside the list | Can change, but the estimate must have used the best information available at the time |
Worked example with made-up numbers: your Loan Estimate shows $2,000 in total for the 10% group, so the Closing Disclosure total can be up to $2,200. One fee can jump more than 10% if the whole group stays under that line.
How to compare Closing Disclosure to Loan Estimate
- Check the loan terms
Compare loan amount, type, term, rate and monthly payment. Confirm there's no prepayment penalty you didn't agree to.
- Check APR and points
Look for a higher APR, new points or a smaller lender credit.
- Sort the changed fees
Place each fee that moved in the table's three groups, then total the 10% group on both forms.
- Review cash to close and escrow
Confirm the tax and insurance amounts look realistic against your actual bills.
- Ask in writing
Email your loan officer or settlement agent a numbered list, and request a corrected form for anything wrong.
- Compare again at closing
Bring your copy and check it against the final documents. CFPB says to take all the time you need.
Closing Disclosure vs Loan Estimate differences by state
The federal fee rules apply nationwide, but closings don't look the same everywhere. A title agent, an escrow agent or a closing attorney may run yours, so ask early who will send your documents.
Transfer taxes and property taxes are set by state and local governments, so those lines differ by location. If an escrow figure looks low, compare it with the county's tax bill for the home.
Closing Disclosure errors to watch for
- Emails with last-minute wire instructions. CFPB warns these may be scams. Confirm by calling a number you saved earlier.
- A higher APR with no explanation. CFPB calls the APR an easy way to spot that costs went up.
- A capped fee that rose. A lender can raise one if you asked for a change or your financial information changed, so ask what changed.
- A smaller lender credit. It counts as a cost increase unless a valid change explains it.
- Misspelled names or a wrong address on any document.
If a lender won't explain a fee, you can ask a real estate attorney to review the file or submit a complaint to CFPB. This is general information, not legal advice.
Closing Disclosure vs Loan Estimate questions
Can closing costs change after the Loan Estimate?
Yes, but the limits depend on the fee. Fees paid to the lender generally can't rise, some third-party and recording fees can rise 10% as a group, and items like prepaid interest and insurance premiums have no set cap.
Does a change to the Closing Disclosure delay closing?
Only if the APR becomes inaccurate, the loan product changes, or a prepayment penalty is added. Those restart the three-business-day wait. Other changes just need a corrected form by the time you close.
What if I got my Closing Disclosure less than three days before closing?
The law requires you to receive it at least three business days ahead. Contact your lender right away and ask how they'll fix the timing. Don't sign until you've received and reviewed it.
Sources: CFPB
General guidance for U.S. homes, not professional advice. For gas, electrical and structural work, call a licensed pro.