TRID Compliance Check — Loan Estimate to Closing Disclosure Reconciliation
Reconcile a residential mortgage closing package for TRID compliance - every fee checked against its good-faith tolerance bucket, the LE and CD timing windows tested, APR accuracy screened, and any borrower cure computed, each value cited to 12 CFR 1026.19.
Full-scope TRID data capture and LE-to-CD tolerance reconciliation with cited evidence on every closing, as a drop-in replacement for offshore first-pass document review
per loan file
What it extracts
14 extraction fields
- Loan and File Summary
- The identifying spine of the file - file and loan numbers, purpose, product, type, term, amount, property, and the lender and settlement agent - so a reviewer can orient before the compliance analysis (12 CFR 1026.37 / 1026.38).
- Disclosure Inventory and Timing
- The inventory of every LE, revised LE, and CD in the file with the governing dates, and the two core TRID timing tests - LE within three business days of application (1026.19(e)(1)(iii)) and CD received at least three business days before consummation (1026.19(f)(1)(ii)).
- Loan Terms
- The Closing Disclosure Loan Terms table - loan amount, interest rate, monthly principal and interest, prepayment penalty, and balloon payment - with the 'can this increase after closing?' answers (1026.38(b)).
- Projected Payments
- The Projected Payments schedule - one row per payment period with principal and interest, mortgage insurance, estimated escrow, and the estimated total monthly payment (1026.38(c)).
- Loan Disclosures
- The CD page-4 loan disclosures - assumption, demand feature, late payment, negative amortization, partial payments, security interest, and the escrow account (1026.38(l)).
- Loan Calculations
- The CD Loan Calculations values - Total of Payments, Finance Charge, Amount Financed, APR, and Total Interest Percentage - that feed the APR and finance-charge accuracy check (1026.38(o)).
- Itemized Closing Costs
- Every closing-cost line item from the CD Closing Cost Details (sections A-C and E-H), one row per fee with the paid-by breakdown, consolidating the separate section tables into one clean fee ledger (1026.38(f)-(h)).
- Fee Tolerance Reconciliation
- The core TRID test - each fee reconciled LE-to-CD and classified into its good-faith tolerance bucket (zero, 10% cumulative, or no tolerance), with the baseline used, the variance, and whether it is within tolerance; the 10% bucket is tested in the aggregate (1026.19(e)(3)).
- Cash to Close Reconciliation
- The Calculating Cash to Close table reconciled LE-to-Final line by line, confirming the on-form 'Did this change?' explanation is present wherever a line changed (1026.38(i)).
- APR and Finance Charge Accuracy
- The APR and finance-charge accuracy screen - disclosed values, whether the transaction is regular or irregular, the applicable APR tolerance (0.125 or 0.25 percentage point), and a plausibility assessment flagging any APR that needs full recalculation (1026.22).
- Tolerance Cure Assessment
- For each charge over its tolerance, the cure the creditor owes the borrower - the overage as the cure amount for zero-tolerance fees, the amount over 110% for the 10% bucket - and the 60-calendar-day corrected-CD and refund deadline (1026.19(f)(2)(v)).
- Contact Information
- The CD page-5 contact table - one row per party (lender, brokers, settlement agent) with the name, address, NMLS or state license ID, contact person, email, and phone (1026.38(r)).
- Compliance Determination
- The single overall disposition for the file - compliant, a tolerance-cure violation, a timing violation, an APR / finance-charge violation, multiple violations, or incomplete - weighing the timing, tolerance, APR, and cure results.
- Compliance Exceptions Log
- The exception log - one row per tolerance overage, timing miss, APR concern, or disclosure gap, each with the cited rule, a severity, the detail, and a concrete corrective action for the reviewer.
Where it fits
Mortgage closing / post-closing TRID compliance review
Upstream
Loan closing - the executed closing package (Loan Estimate, any revised LE, Closing Disclosure, and supporting closing documents) arriving from the settlement agent, the loan origination system, or a due-diligence intake queue
This step
TRID compliance check - LE-to-CD fee reconciliation, tolerance-bucket testing, disclosure-timing verification, APR and finance-charge accuracy, and cure calculation
Downstream
- Post-closing QC exception clearing and cure / refund processing
- Loan due-diligence grading and investor delivery
- Regulatory exam and audit reporting
What it needs
Documents
- Loan Estimate (LE)
- Revised Loan Estimate(s)
- Closing Disclosure (CD)
- Corrected Closing Disclosure(s)
- Closing package / settlement statement
- Changed-circumstance documentation
Systems
- Loan origination system (LOS)
- Document repository / imaging system
- Due-diligence or QC platform
Prerequisites
- Both the Loan Estimate (most recent, including any revised LE) and the Closing Disclosure for the same loan in the file
- Any changed-circumstance documentation that reset a tolerance baseline
- Your institution's TRID tolerance policy and provider list for edge-case classification
What it produces
A per-loan TRID compliance record - the LE and CD field sets, a fee-by-fee tolerance reconciliation with bucket assignment, the disclosure-timing assessment, APR and finance-charge accuracy, any cure amount owed to the borrower with its 60-day deadline, an overall compliance determination, and a cited exceptions log
Delivered to
- Post-closing QC exception queue
- Cure / refund processing
- Due-diligence grading dataset
- Audit / exam evidence file
Review model
A compliance or post-closing QC reviewer confirms the flagged tolerance overages, timing exceptions, and cited findings before a cure is issued or the file is cleared for delivery.
Who uses it
Volume fit
Works best for
lenders, servicers, and due-diligence firms reviewing hundreds or thousands of closings a month who need consistent, cited TRID data capture instead of offshore first-pass review
Too small for
a one-off single-file review with no repeatable closing volume
Grounded in
- TILA-RESPA Integrated Disclosure rule / Regulation Z, 12 CFR 1026.19(e) and (f)verified as of 2026-07-22
- 12 CFR 1026.19(e)(3) (Good-faith tolerance categories: zero, 10% cumulative, no tolerance)verified as of 2026-07-22
- 12 CFR 1026.19(e)(1)(iii), 1026.19(f)(1)(ii), and 1026.19(e)(4) (Disclosure timing and revised-disclosure windows)verified as of 2026-07-22
- 12 CFR 1026.19(f)(2)(v) (Cure - refund and corrected Closing Disclosure within 60 days)verified as of 2026-07-22
- 12 CFR 1026.37 (Loan Estimate content) and 12 CFR 1026.38 (Closing Disclosure content)verified as of 2026-07-22
- 12 CFR 1026.22 (Annual percentage rate accuracy tolerances)verified as of 2026-07-22
Changelog
- July 2026
based on a production deployment at a residential-mortgage operations provider
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Disputes / Complaints Management
First-pass review of a consumer dispute or complaint - code the reason, pin the governing regime (Reg E, Reg Z, or FCRA), test the response and provisional-credit deadlines, weigh the evidence, and recommend a disposition, every timeline finding cited.
See TRID Compliance Check — Loan Estimate to Closing Disclosure Reconciliation on your documents
We'll run it against a file of yours and walk through every cited field.