TRID Tolerance Buckets: Zero, 10% and Unlimited Fees Explained
Every closing cost on the Loan Estimate lands in one of three tolerance buckets, and the bucket decides whether the creditor owes the borrower money when the fee rises at closing. Test questions give you a list of fees, who was paid and who picked the provider, then ask which increase must be refunded and how much. The rules below are from 12 CFR 1026.19(e)(3) and its official interpretations, as at 11 Oct 2026.
The three buckets
Good faith is measured by comparing the amount the borrower actually pays at consummation (or settlement, if later) with the amount on the original Loan Estimate. A revised Loan Estimate resets the baseline only when it was issued for a valid reason such as a changed circumstance or a borrower-requested change (12 CFR 1026.19(e)(3)(iv)).
| Bucket | What goes in it | How much it may rise |
|---|---|---|
| Zero tolerance | Fees paid to the creditor, the mortgage broker or an affiliate of either; fees to an unaffiliated provider the borrower was not allowed to shop for; transfer taxes; lender credits (a decrease counts as an increase in cost) | Not at all. Any increase must be refunded. |
| 10% aggregate | Recording fees; fees to an unaffiliated provider for a service the borrower was allowed to shop for, where the borrower chose from the creditor's written list or chose no one | The total of the bucket may rise by up to 10% of the Loan Estimate total. |
| Unlimited (good faith) | Prepaid interest; property insurance premiums; initial escrow deposits; property taxes; shoppable services where the borrower chose a provider not on the list; services the creditor does not require | Any amount, if the estimate used the best information reasonably available. |
Two questions sort almost every fee
- Who keeps the fee? If the creditor, the broker or an affiliate of either keeps it, the fee is zero tolerance. That stays true even when the borrower picked the affiliate from the written list (comment 19(e)(3)(ii)-6).
- Could the borrower shop, and whom did they choose? Not allowed to shop: zero tolerance. Allowed to shop and chose from the list, or chose no one: 10% bucket. Allowed to shop and chose a provider not on the list: unlimited.
- Recording fees go to a government office, so the affiliate and shopping conditions do not apply; they are always in the 10% bucket (comment 19(e)(3)(ii)-4).
- Transfer taxes are zero tolerance, even though they also go to a government office (comment 19(e)(3)(i)-1).
How the 10% test works
- Add up every 10%-bucket fee on the Loan Estimate, then multiply by 1.10. That is the limit.
- Compare the limit with the total actually paid for the same bucket. One fee can rise by more than 10% with no violation if the total stays within the limit (comment 19(e)(3)(ii)-2).
- A 10%-bucket fee that was left off the Loan Estimate but charged at closing still counts in the closing total.
- A service on the Loan Estimate that was never performed comes out of the Loan Estimate total before you multiply (comment 19(e)(3)(ii)-5).
Curing a tolerance violation
If the borrower paid more than the tolerance allows, the creditor cures by refunding the excess no later than 60 days after consummation and by delivering or mailing a corrected Closing Disclosure that reflects the refund within the same 60 days (12 CFR 1026.19(f)(2)(v)). For a zero-tolerance fee, the refund is the whole increase. For the 10% bucket, it is only the amount above 110% of the Loan Estimate total.
Worked example: sorting fees and computing the cure
Loan Estimate, 10% bucket: recording $125; title services (provider from the written list) $1,450; survey (from the list) $400; pest inspection (from the list) $100. Total $2,075.
The pest inspection was never done, so remove it: $2,075 - $100 = $1,975. Limit = $1,975 x 1.10 = $2,172.50.
At closing, 10% bucket: recording $140; title $1,650; survey $425; a $35 notary fee from the listed settlement agent that was not on the Loan Estimate. Total $2,250. Excess = $2,250 - $2,172.50 = $77.50.
Zero bucket: the creditor's origination fee rose from $1,200 to $1,275 with no changed circumstance. Excess = $75.
Unlimited bucket: the homeowners insurance premium rose from $1,320 to $1,480. No cure, because it was estimated in good faith.
Total cure = $77.50 + $75 = $152.50. Consummation was Monday, March 2, 2026, so the refund and corrected Closing Disclosure are due no later than Friday, May 1, 2026 (60 days later).
Exam trap
Exam takeaway
Drill the buckets with our practice TRID questions, read the TRID study note, and keep the TRID timeline cheat sheet for the dates.
Frequently asked questions
What fees are zero tolerance under TRID?
Fees paid to the creditor, the mortgage broker or an affiliate of either, fees for services the borrower could not shop for, transfer taxes, and decreases in lender credits (12 CFR 1026.19(e)(3)(i) and comment 19(e)(3)(i)-1).
What fees are in the 10% tolerance bucket?
Recording fees, and fees to unaffiliated providers for services the borrower could shop for when the borrower chose from the creditor's written list or chose no one. The bucket total may rise by up to 10% (12 CFR 1026.19(e)(3)(ii)).
Is the 10% tolerance per fee or in total?
In total. One fee can rise by more than 10% as long as the sum of all 10%-bucket fees stays within 110% of the Loan Estimate sum (comment 19(e)(3)(ii)-2).
How long does a lender have to cure a tolerance violation?
The excess must be refunded, with a corrected Closing Disclosure, no later than 60 days after consummation (12 CFR 1026.19(f)(2)(v)).
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