Strict TRID fee category whose charges generally cannot exceed the applicable Loan Estimate baseline.
Zero-tolerance charges are mortgage closing charges that generally cannot exceed the amount disclosed on the applicable Loan Estimate. A valid reason and properly timed revised disclosure may create a new comparison baseline.
The phrase zero tolerance is common mortgage-industry shorthand. The regulation frames the issue as whether an estimated closing cost was disclosed in good faith. For the strictest category, an amount paid by or imposed on the borrower generally cannot exceed the disclosed estimate.
This category helps prevent a lender from attracting a borrower with understated charges it controls and then increasing those charges at closing. It also gives the borrower a structured way to compare the Loan Estimate with the Closing Disclosure.
An increase is not automatically measured against the first Loan Estimate forever. If a permitted event, such as a valid Changed Circumstance, supports a timely Revised Loan Estimate, that revised amount may become the applicable baseline for the affected charge.
Borrowers first see these charges on the Loan Estimate and evaluate them again near closing. Charges generally associated with the strict category include:
A reduction in disclosed lender credits can also function as an increased cost to the borrower for this comparison. The actual classification depends on who receives the charge and whether the borrower was permitted to choose the provider, not merely the fee label.
The term becomes most practical when the borrower compares the final charge with the correct estimate and asks whether a Tolerance Cure appears as a lender credit or refund.
| Fee situation | Usual treatment |
|---|---|
| Charge retained by lender, broker, or affiliate | Strict category |
| Required service with no borrower shopping choice | Strict category |
| Transfer tax | Strict category |
| Eligible recording fee or listed unaffiliated shoppable service | 10% cumulative category |
| Prepaid interest, property insurance, escrow deposits, or certain borrower-selected services | May vary if estimated using the best information reasonably available |
These are categories for testing estimates, not a promise that every dollar on the Loan Estimate will remain unchanged.
A Loan Estimate shows a $1,100 lender origination charge. The Closing Disclosure shows $1,250 for the same charge. No valid revised disclosure changed the baseline.
The $150 increase exceeds the strict estimate. The lender generally cannot simply reclassify the amount as an ordinary cost change; the excess must be addressed through the applicable cure process.
Now assume the borrower requested a different loan product and a permitted revision accurately increased the origination charge to $1,250. If the revised disclosure was supported and timely, $1,250 may be the valid comparison baseline instead.
The name of a fee is not enough. For example, money collected by a lender and passed through to an unaffiliated appraiser is not necessarily a fee paid to the lender for tolerance purposes.
Zero-tolerance charges differ from a Changed Circumstance because the first is a fee-limit category and the second is a possible reason a lender may revise an estimate.
They also differ from a Tolerance Cure, which is the correction after the lender has to fix an overage.
They differ from 10% Cumulative Tolerance because eligible charges in that category are tested as a group and may rise by up to 10% in total. Strict-category charges are generally tested individually against the applicable estimate.