When your lender delivers the Closing Disclosure for your refinance, you have three business days to review it before signing — and that window is not a formality. It is your last opportunity to catch errors, question fees, and confirm that the loan terms you were quoted are the terms you are actually closing on.
For refinance borrowers in Virginia, Florida, Tennessee, and Georgia, a single overlooked line item can cost hundreds or even thousands of dollars over the life of the loan. The CFPB mandates this three-day review period precisely because the CD contains binding financial details: your final interest rate, APR, monthly payment, closing costs, cash-out proceeds if applicable, and loan program specifics.
Many borrowers glance at the total cash-to-close figure and stop there. That approach leaves real money on the table.
This guide walks through eight targeted strategies for reviewing your Closing Disclosure — not as a passive reader, but as an informed borrower who knows exactly what to look for, what to challenge, and how to protect your refinance outcome. Whether you are completing a rate-and-term refinance, a VA IRRRL, a cash-out refi, or an FHA Streamline, the CD review process follows the same critical framework.
Duane Buziak, NMLS #1110647 | Coast2Coast Mortgage LLC, NMLS #376205
1. Match Your Loan Estimate to the CD Line by Line
The Challenge It Solves
Most CD errors are not discovered because borrowers do not have their Loan Estimate in hand when they open the Closing Disclosure. The two documents are designed to be read together. Without the LE as a reference, you have no baseline for what fees were originally quoted — and no way to identify which increases are regulatory violations versus allowable adjustments.
The Strategy Explained
The CFPB’s TRID rule divides closing costs into three tolerance categories. Zero-tolerance fees cannot increase at all from LE to CD — any increase requires a lender cure. Ten-percent aggregate tolerance fees can increase, but only up to 10% collectively. Unlimited tolerance fees, such as prepaid interest and insurance premiums, can change without restriction.
Pull out your original Loan Estimate and place it side by side with your CD. Go section by section: origination charges, third-party services, recording fees, prepaids, and escrow. Mark every line where the CD number differs from the LE number. Then categorize each difference by tolerance bucket before deciding whether to flag it.
Implementation Steps
1. Locate your Loan Estimate — it was issued within three business days of your application. If you cannot find it, request a copy from your loan officer before the CD arrives.
2. Open both documents to the closing cost sections and create a simple two-column comparison: LE amount on the left, CD amount on the right, difference in the middle.
3. Classify each changed fee as zero-tolerance, 10%-tolerance, or unlimited-tolerance using the CFPB framework. Any zero-tolerance increase is a lender cure situation — document it and contact your loan officer immediately.
Pro Tips
Request your CD electronically so you can copy figures into a spreadsheet. A side-by-side digital comparison is faster and less prone to transcription errors than flipping between paper pages. Keep a timestamped record of when you received the CD — your three-day window starts from confirmed receipt, not from the date printed on the document.
2. Verify Your Interest Rate, APR, and Loan Type Are Locked In
The Challenge It Solves
Page 1 of the Closing Disclosure contains the most consequential numbers in the entire document: your loan amount, interest rate, monthly principal and interest payment, and whether your rate is fixed or adjustable. Errors on this page are rare but catastrophic when they occur — and they are easy to miss if you do not know exactly what your rate lock confirmation stated.
The Strategy Explained
Pull your rate lock confirmation and compare it directly to the Loan Terms table on Page 1 of the CD. Your interest rate on the CD must match your locked rate exactly, including decimal places. The loan type field must reflect the correct program: conventional, FHA, VA, or USDA. If you locked a fixed rate, the CD must not show an adjustable-rate product.
The APR will always be higher than your interest rate — that is expected and not an error. The APR incorporates prepaid finance charges including origination fees, discount points, and certain third-party costs. What you are checking is whether the APR spread is consistent with what your lender disclosed. A significantly wider APR spread than expected can signal that additional fees were added to the loan without your knowledge. According to Freddie Mac’s Primary Mortgage Market Survey, tracking current benchmark rates gives you a reference point for whether your locked rate remains competitive at closing.
Implementation Steps
1. Locate your rate lock confirmation email or document. Confirm the locked rate, lock expiration date, and loan program match what appears on Page 1 of the CD.
2. Check the fixed/adjustable designation explicitly. If your loan is fixed, the “Can this amount increase after closing?” field next to the interest rate should read “No.”
3. Review the APR and compare it to the APR shown on your Loan Estimate. A meaningful increase in APR from LE to CD warrants a direct question to your loan officer about which fees changed.
Pro Tips
If your rate lock expired and was extended before closing, confirm that any rate lock extension fee was properly disclosed. Extension fees fall under zero-tolerance rules if they were not anticipated — an undisclosed extension fee added to your closing costs is a cure situation.
3. Audit Section A and Section B Fees for Unexpected Charges
The Challenge It Solves
Section A of the CD lists origination charges: lender fees, origination points, application fees, underwriting fees, and processing fees. These are zero-tolerance items — they cannot increase from the Loan Estimate to the Closing Disclosure under any circumstances. Yet processing fees, administrative fees, and document preparation charges sometimes appear on CDs without appearing on the original LE, which is a direct TRID violation.
The Strategy Explained
Review every line in Section A with the assumption that any new fee or any fee increase is a lender cure situation until proven otherwise. Section B covers services where you were not permitted to shop — appraisal, credit report, flood determination, and similar items. These are also zero-tolerance. Section C covers services where you were permitted to shop; these fall under the 10% aggregate tolerance bucket.
Here is a worked dollar example using a $300,000 refinance. Your Loan Estimate shows a processing fee of $0 — meaning the lender disclosed no separate processing charge. Your Closing Disclosure shows a processing fee of $450. Because processing fees are a Section A origination charge, this is a zero-tolerance violation. The lender must credit you $450 at closing or before. Your monthly payment is unaffected, but your cash-to-close is $450 higher without the correction. That $450 cure must appear as a lender credit on the CD before you sign.
A broker’s CD may show lower Section A origination charges than a retail lender CD because wholesale lenders compete for broker business — meaning Coast2Coast Mortgage LLC’s access to multiple wholesale lenders can result in reduced or eliminated origination fees compared to what Rocket Mortgage or Movement Mortgage might show on their retail CDs.
Implementation Steps
1. List every Section A line item from your LE and compare it to every Section A line item on your CD. Any fee that appears on the CD but not the LE is a potential zero-tolerance violation.
2. For Section B, repeat the comparison. Flag any fee that increased, even by a small amount.
3. For Section C, total all the fees from both documents and calculate the aggregate change. If the aggregate increase exceeds 10%, the lender owes a cure for the overage.
Pro Tips
Watch for fees that are renamed between the LE and CD. A “processing fee” on the LE that becomes an “administrative fee” on the CD is still the same zero-tolerance charge — the label change does not convert it to a different tolerance category.
4. Confirm Cash-Out Proceeds or Payoff Amounts Match Your Expectations
The Challenge It Solves
For cash-out refinance borrowers, the CD must show both the new loan amount and the net cash proceeds you will receive after your existing mortgage is paid off and closing costs are settled. Errors in the payoff figure — even small ones — directly reduce the cash you walk away with. For VA cash-out borrowers specifically, the loan amount on the CD must reflect the correct LTV ceiling.
The Strategy Explained
VA cash-out refinance allows eligible veterans to borrow up to 100% of the appraised value of their home — not 90%, not 95%, but 100% LTV as confirmed by VA.gov’s home loan program guidelines. If your CD shows a loan amount that reflects a lower LTV ceiling, that is an error that reduces your available proceeds and must be corrected before closing.
Here is a worked example. A veteran owns a home appraised at $400,000 with an existing balance of $280,000. VA cash-out to 100% LTV means the maximum new loan amount is $400,000 (minus the VA funding fee if financed, which would be added to the loan). If the CD shows a loan amount of $360,000, that reflects 90% LTV — incorrect for VA. The borrower is leaving $40,000 in available equity on the table due to a program error on the CD.
For conventional and FHA cash-out borrowers, verify the payoff figure against your most recent mortgage statement. Payoff amounts include per-diem interest through the expected closing date — confirm that the payoff figure on the CD aligns with a payoff quote from your current servicer.
Implementation Steps
1. Request a formal payoff quote from your current mortgage servicer dated through your anticipated closing date. Compare this figure to the payoff amount shown in the CD’s Payoff section.
2. For VA cash-out, verify the new loan amount reflects 100% LTV based on the appraised value — not a reduced LTV ceiling applied in error.
3. Calculate your expected net proceeds: new loan amount minus existing payoff minus closing costs. Confirm this matches what you were quoted during the application process.
Pro Tips
If your closing date shifts after the CD is issued, your payoff amount will change due to additional per-diem interest accruing on your existing loan. Request an updated payoff quote if closing is delayed by more than a few days, and verify the CD is updated accordingly.
5. Review Prepaid Items and Escrow Setup for Accuracy
The Challenge It Solves
Prepaid items and escrow setup fall under unlimited tolerance — meaning they can change from the LE to the CD without triggering a lender cure. But that does not mean errors do not occur. Incorrect per-diem interest calculations, wrong insurance premium figures, and inflated escrow cushion amounts are common and can add hundreds of dollars to your cash-to-close without any regulatory protection requiring the lender to fix them.
The Strategy Explained
Prepaid daily interest is calculated based on your closing date within the month. The later in the month you close, the fewer days of prepaid interest you owe — because your first payment is due on the first of the month following a full month after closing. Here is the math on a real loan figure.
On a $300,000 loan at 6.75%, the daily interest rate is calculated as: $300,000 multiplied by 0.0675, divided by 365, which equals $55.48 per day. If you close on the 20th of a 30-day month, you owe 10 days of prepaid interest: $55.48 multiplied by 10 equals $554.80. Verify this figure matches what the CD shows in the Prepaids section. A calculation error using the wrong loan balance or wrong rate will produce an incorrect prepaid interest charge.
For escrow setup, the CD must show your homeowners insurance premium accurately. Confirm this matches your actual policy renewal amount, not an estimated figure. The escrow cushion — typically two months of taxes and insurance — must also be verified against your actual property tax bill and insurance premium.
Implementation Steps
1. Calculate your own per-diem interest using the formula above and compare it to the CD figure. Any discrepancy of more than a dollar or two warrants a question to your loan officer.
2. Pull your current homeowners insurance declarations page and confirm the annual premium on the CD matches your actual policy cost.
3. Review your most recent property tax bill and verify the monthly escrow contribution on the CD is based on your actual tax obligation, not an outdated or estimated amount.
Pro Tips
Closing earlier in the month means more prepaid interest days — and higher cash to close for that line item. If you have flexibility on your closing date, closing in the last week of the month minimizes prepaid interest and reduces your immediate out-of-pocket cost at the table.
6. Check the Loan Terms Table for Program-Specific Accuracy
The Challenge It Solves
VA IRRRL, FHA Streamline, and conventional refinance borrowers each have program-specific line items that must appear correctly on the CD. A VA funding fee waiver that does not appear, an incorrect MIP schedule on an FHA loan, or a missing PMI cancellation provision on a conventional refi can all create financial consequences that extend well beyond the closing table.
The Strategy Explained
For VA IRRRL borrowers, the CD must reflect the correct VA funding fee. Veterans with a service-connected disability rating of 10% or higher are exempt from the VA funding fee — this waiver must appear explicitly on the CD as a credit or as a $0 line item. If the funding fee is charged to a veteran who qualifies for a waiver, the lender must correct it before closing. Confirm your eligibility by reviewing your Certificate of Eligibility and disability rating documentation. The VA IRRRL program page confirms funding fee rates and waiver eligibility criteria.
For FHA Streamline borrowers, the CD must reflect the correct upfront mortgage insurance premium and the correct annual MIP rate. HUD’s FHA Streamline guidelines specify that no appraisal and no income verification are required — if your CD shows appraisal charges for an FHA Streamline, that is an error.
For conventional refinance borrowers, if your new loan-to-value ratio is below 80%, PMI should not appear on the CD at all. If you are refinancing into a loan amount that falls within the 2026 FHFA conforming limit of $806,500 for standard markets, verify that your loan is correctly classified as conforming — not jumbo — and that the program terms reflect conforming guidelines.
Implementation Steps
1. VA borrowers: Locate your funding fee amount on the CD and cross-reference it with your disability rating. If you qualify for a waiver, the fee must not appear as a charge.
2. FHA borrowers: Confirm the upfront MIP amount and annual MIP rate match current HUD schedule rates for your loan term and LTV. Confirm no appraisal fee appears for a Streamline transaction.
3. Conventional borrowers: Verify PMI status based on your new LTV. If your loan amount exceeds $806,500 in a standard market, confirm the CD reflects jumbo program terms rather than conforming guidelines.
Pro Tips
If you are a disabled veteran and your funding fee waiver was not processed correctly, do not proceed to closing until it is corrected. This is not a minor adjustment — on a $350,000 VA loan, the funding fee at the standard rate represents a meaningful dollar amount that you are legally entitled to have waived.
7. Scrutinize the Calculating Cash to Close Table
The Challenge It Solves
Page 3 of the Closing Disclosure contains the Calculating Cash to Close table — and this is where errors from multiple earlier sections compound into a single final number. A missing lender credit, a misapplied deposit, or an incorrectly carried closing cost subtotal can inflate your cash-to-close figure without any single line item appearing obviously wrong. This table requires its own dedicated review pass after you have verified all upstream sections.
The Strategy Explained
The Calculating Cash to Close table reconciles your LE figures against your CD figures and shows the final amount you need to bring to closing. Every lender credit, seller concession, deposit, and closing cost feeds into this calculation. An error anywhere upstream — a missing credit, a duplicated fee, an incorrect payoff — will surface here as an unexplained difference.
Here is a worked dollar example. On a $275,000 rate-and-term refinance, your Loan Estimate showed a $600 lender credit. Your Closing Disclosure omits that credit entirely. The LE showed cash to close of $2,100. The CD shows cash to close of $2,700. The $600 difference is not a rounding issue — it is a missing lender credit that must be restored before you sign. Without flagging this during your three-day review window, you pay $600 more at closing than you were quoted, with no recourse after the fact.
Work through the table systematically: confirm the closing costs total matches what you calculated in your section-by-section audit, confirm all lender credits appear, and confirm your deposit or earnest money is properly credited if applicable to your refinance transaction.
Implementation Steps
1. Add up all closing costs from Sections A through H on your CD independently. Confirm that total matches the closing costs figure shown in the Calculating Cash to Close table.
2. List every credit that appeared on your LE — lender credits, discount point rebates, seller concessions — and verify each one appears on the CD in the correct amount.
3. Calculate the difference between your LE cash-to-close and your CD cash-to-close. If the CD is higher, identify which specific line items account for the increase and determine whether each increase is permissible under TRID tolerance rules.
Pro Tips
If you financed your closing costs into the loan on a no-cost refinance structure, verify that the lender credit covering those costs appears correctly on the CD. A no-cost refinance where the lender credit disappears from the CD is not a no-cost refinance — it is a full-cost refinance with a higher rate than you agreed to.
8. Use the Three-Day Window Strategically — Then Ask the Right Questions
The Challenge It Solves
Most borrowers treat the three-day review period as a waiting period rather than an action period. The window exists to give you time to identify errors, request corrections, and receive a revised CD if necessary. But using it effectively requires knowing who owns which line items, how to formally request a correction, and how to protect your credit score if you are still in active rate-shopping mode when the CD arrives.
The Strategy Explained
When you identify a discrepancy, contact your loan officer in writing — email is sufficient — and specify the exact line item, the LE amount, the CD amount, and the tolerance category you believe has been violated. Your loan officer owns Section A origination charges and any lender credits. Title company errors in Section B or C are coordinated through your loan officer but originate with the title provider. Escrow and prepaid errors are typically corrected by the closing agent.
If a correction requires a revised CD to be issued, your three-day review window resets from the date you receive the corrected document. This is a consumer protection — not an inconvenience. Use it.
Here is where the NoTouch Credit Pull matters for borrowers who are still comparing options when the CD arrives. Our NoTouch Credit Pull process at Coast2Coast Mortgage LLC allows borrowers to explore refinance options using a soft credit pull mortgage approach — meaning no hard inquiry is triggered during the rate-shopping phase. This is a meaningful protection: borrowers who rate-shopped through multiple lenders using hard pulls may arrive at CD review with a lower credit score than when they started, which can affect their final loan terms. A no hard inquiry mortgage pre approval through a soft pull mortgage broker like Coast2Coast means your score is protected throughout the process.
For borrowers who want to verify they have the most competitive terms before signing, a mortgage pre approval without hard pull lets you confirm your rate against the market without credit score consequences. This no credit hit mortgage application approach is especially valuable in the final days before closing, when you want information without risk.
Implementation Steps
1. Send a written correction request for every discrepancy you identify, specifying the line item, the dollar difference, and the tolerance category. Keep a copy of every communication with timestamps.
2. Confirm with your loan officer whether a correction requires a revised CD. If it does, note the new three-day window start date from confirmed receipt of the revised document.
3. If you have questions about whether your rate remains competitive relative to current market conditions, request a soft credit pull mortgage rate check through your broker — not a new hard inquiry — before proceeding to sign.
Pro Tips
Do not sign under pressure if your three-day window has not expired and you still have unresolved questions. Your closing date can be adjusted if corrections are needed. A one-day delay to get a $450 lender cure properly documented is worth far more than the inconvenience of rescheduling.
Broker vs. Retail Lender: What Your CD Might Look Like
The structure of your lender relationship affects what appears on your Closing Disclosure before you even begin reviewing it. The following comparison reflects the structural differences between a wholesale mortgage broker and a retail lender — not a guarantee of specific rates or fees, which vary by loan scenario and borrower profile.
| Factor | Coast2Coast Mortgage LLC (Broker) | Retail Lender (e.g., Rocket Mortgage) |
|---|---|---|
| Interest Rate Source | Wholesale pricing from 500+ lenders — competitive across multiple rate shelves | Single lender’s retail rate shelf |
| Section A Origination Fees | May be lower — wholesale lenders compete for broker business | Set by single retail lender’s fee schedule |
| Cash-Out LTV Ceiling (VA) | 100% LTV — program maximum always applied correctly | 100% LTV — verify on CD that retail lender applies correctly |
| VA IRRRL Access | Yes — through VA-approved wholesale lenders | Yes — direct retail origination |
| FHA Streamline Access | Yes — through FHA-approved wholesale lenders | Yes — direct retail origination |
| FICO Floor Flexibility | Varies by wholesale lender — multiple options for lower-score borrowers | Set by single lender’s overlay policy |
| CD Review Support | Broker reviews CD with borrower line by line before closing | Varies by lender — typically self-service review |
Frequently Asked Questions
What is a Closing Disclosure and when do I receive it for a refinance?
A Closing Disclosure is a five-page federal form that details the final terms and costs of your mortgage refinance, including your interest rate, monthly payment, closing costs, and cash-to-close amount. For a refinance, your lender must deliver the CD at least three business days before your scheduled closing date, as required by the CFPB’s TRID rule.
How many days do I have to review my Closing Disclosure before closing?
You have three business days to review your Closing Disclosure before you can sign your final loan documents. This waiting period is mandated by federal law and cannot be waived except in narrow circumstances involving a bona fide personal financial emergency. If a revised CD is issued due to corrections, the three-day window resets from confirmed receipt of the revised document.
What fees on the Closing Disclosure cannot increase from my Loan Estimate?
Zero-tolerance fees cannot increase at all from your Loan Estimate to your Closing Disclosure. These include origination charges in Section A, transfer taxes, and fees for required third-party services where you were not permitted to shop. Any increase in a zero-tolerance fee requires the lender to issue a cure — a credit to the borrower — before or at closing.
What should I check first on my Closing Disclosure for a VA refinance?
For a VA refinance, check your funding fee status first. If you have a service-connected disability rating of 10% or higher, you are exempt from the VA funding fee and it must not appear as a charge on your CD. For a VA cash-out refinance, verify the loan amount reflects 100% LTV based on the appraised value — not a reduced LTV ceiling applied in error by the lender.
Can my interest rate change between the Loan Estimate and Closing Disclosure?
Your interest rate cannot change from the Loan Estimate to the Closing Disclosure if you have a valid rate lock in place. If your rate lock expired before closing and was extended or re-locked at a different rate, the lender must have disclosed the rate change and any associated extension fees. Confirm your CD rate matches your rate lock confirmation document exactly, including decimal places.
What is the difference between APR and interest rate on a Closing Disclosure?
The interest rate on your Closing Disclosure is the base rate used to calculate your monthly principal and interest payment. The APR is always higher than the interest rate because it incorporates prepaid finance charges — including origination fees, discount points, and certain third-party costs — spread over the loan term. A significantly wider APR spread on the CD compared to the Loan Estimate can indicate that additional fees were added to the loan without prior disclosure.
How do I dispute an error on my Closing Disclosure before closing?
To dispute an error on your Closing Disclosure, contact your loan officer in writing — email is sufficient — and identify the specific line item, the Loan Estimate amount, the CD amount, and the tolerance category you believe was violated. Your loan officer is responsible for coordinating corrections with the lender and title company. If the correction requires a revised CD, your three-day review window resets from the date you receive the corrected document.
Does reviewing my Closing Disclosure trigger a hard credit inquiry?
Reviewing your Closing Disclosure does not trigger any credit inquiry — it is simply a document review. However, if you want to compare your final terms against current market rates during your three-day window, use a soft credit pull mortgage approach rather than applying with additional lenders. Coast2Coast Mortgage LLC’s NoTouch Credit Pull process allows borrowers to receive rate comparisons using a soft pull mortgage broker approach — no hard inquiry mortgage pre approval required, and no credit hit mortgage application impact on your score.
Putting It All Together: Your CD Review Roadmap
Reviewing your Closing Disclosure is not about distrust — it is about protecting the financial outcome you negotiated. The three-day review window exists because errors happen, fees shift, and lender systems are imperfect. By working through these eight strategies systematically, you can catch discrepancies before they become binding obligations.
Start with the Loan Estimate comparison in Strategy 1 to establish your baseline. Lock down your rate and APR in Strategy 2. Work through origination fees in Strategy 3, proceeds and payoffs in Strategy 4, prepaids and escrow in Strategy 5, and program-specific terms in Strategy 6. Then reconcile everything in the cash-to-close table in Strategy 7 before using your three-day window strategically in Strategy 8.
If you are refinancing in Virginia, Florida, Tennessee, or Georgia and want a broker who reviews your CD with you line by line before closing, contact Duane Buziak at Coast2Coast Mortgage LLC. Our NoTouch Credit Pull process means you can explore your refinance options — including rate-and-term, cash-out, VA IRRRL, and FHA Streamline — without a hard inquiry hitting your credit report during the shopping phase.
Compare personalized refinance rates now and find out whether a lower rate, reduced monthly payment, or cash-out opportunity is within reach. Call 804-212-8663 to speak directly with Duane Buziak, or start your no credit hit mortgage application today.
