Loan Estimate vs. Closing Disclosure: What to Compare
You get two standardized forms when you take out most home loans. The Loan Estimate arrives within three business days after you apply and shows the expected terms and closing costs. The Closing Disclosure must reach you at least three business days before closing and shows the final numbers. Federal rules limit how much many of the costs can rise between the two, so comparing them line by line is the best way to catch mistakes and surprise fees.
Why the two forms look alike
Since October 2015, both forms follow a design set by the Consumer Financial Protection Bureau. The layouts match on purpose: page 1 shows the loan terms and projected payments, page 2 lists closing costs, and later pages cover cash to close and other disclosures. You can lay them side by side and compare section by section.
They don’t apply to every loan. Home equity lines of credit, reverse mortgages, some manufactured home loans not secured by real estate and certain homebuyer assistance second loans use different disclosures.
Which costs can change, and by how much
Closing costs fall into three groups. Knowing which group a fee belongs to tells you whether an increase is allowed.
| Group | Examples | How much it can increase |
|---|---|---|
| Can’t increase | Lender’s origination charges, points you agreed to pay, transfer taxes, fees paid to the lender’s affiliates, fees for services the lender chose and you couldn’t shop for (such as the appraisal) | Not at all |
| Can increase up to 10% in total | Recording fees, and third-party services you could shop for but chose from the lender’s list (such as title services) | The sum of these fees can rise by no more than 10% |
| Can change | Prepaid interest, homeowners insurance premiums, amounts placed in escrow, services you shopped for yourself from a provider not on the lender’s list | No limit, though they should reflect real costs |
Increases above these limits generally aren’t allowed unless there was a valid “changed circumstance,” such as you changing the loan amount, the appraisal coming in lower, or you choosing to lock the rate later. If the lender charges more than allowed without a valid reason, it must refund the difference.
Changes that restart the three-day clock
Most corrections to the Closing Disclosure don’t delay closing. Three changes do, because they trigger a new Closing Disclosure and a new three-business-day waiting period:
- The APR becomes inaccurate beyond a small tolerance (generally more than 1/8 of a percentage point on most fixed-rate loans, or 1/4 on loans with irregular payments). A lower APR often doesn’t count.
- The loan product changes, for example from a fixed rate to an adjustable rate.
- A prepayment penalty is added.
If you see any of these on a revised form, expect your closing date to move.
Line-by-line comparison checklist
Put the latest Loan Estimate next to the Closing Disclosure and check:
Page 1: loan terms
- Loan amount matches what you agreed.
- Interest rate matches your rate lock.
- Loan type and term (30-year fixed, for example) are unchanged.
- No prepayment penalty or balloon payment you didn’t expect.
- The monthly principal and interest payment matches.
- Estimated escrow (tax and insurance) is reasonable for the property.
Page 2: closing costs
- Section A (origination charges): identical to the Loan Estimate.
- Section B (services you couldn’t shop for): identical, unless there’s a documented reason.
- Section C (services you could shop for): if you used the lender’s list, the total of these plus recording fees is within 10%.
- Section F (prepaids) and G (initial escrow): make sure the property tax and insurance figures match your actual bill and policy.
- No new fees that weren’t on the Loan Estimate.
Page 3: cash to close
- Your deposit (earnest money) is credited.
- Seller credits you negotiated appear.
- The final “cash to close” matches the amount you’re preparing to wire.
Other pages
- Your name and the property address are spelled correctly.
- The total of payments and the APR look consistent with your loan.
What to do if something is wrong
- Ask your loan officer in writing to explain each difference. Many errors are simple data-entry mistakes.
- Ask for the reason for any increase in a fee that shouldn’t change. A lender must document a changed circumstance.
- Request a corrected Closing Disclosure before closing.
- Verify wiring instructions by phone using a number you already know, not one in an email. Closing is a common target for wire fraud.
- If the issue isn’t resolved, you can submit a complaint to the CFPB.
Use the three days
Those three business days exist so you can compare the two forms before you’re sitting at the closing table. Block an hour, go through the checklist above, and send your questions to the loan officer in one email. Most problems are easier to fix on a Tuesday than at the signing on Friday.
Sources
- Consumer Financial Protection Bureau, When do I get a Closing Disclosure?
- Consumer Financial Protection Bureau, Know Before You Owe: Closing Disclosure
- Consumer Financial Protection Bureau, Can my final mortgage costs increase from what was on my Loan Estimate?
This guide is for general information only and is not financial, tax or legal advice. Rules and rates change; confirm details with your county assessor, lender or a licensed professional. See our methodology and editorial policy for how we research and update content, or report an error.