Costs That Can Increase on Your Houston Loan Estimate

Receiving your initial Loan Estimate (LE) is an exciting step, but it's crucial to understand that it is just that: an estimate. The TILA-RESPA Integrated Disclosure (TRID) rule, enforced by the Consumer Financial Protection Bureau (CFPB), categorizes closing costs into three groups based on how much they can change by your closing day. Understanding these categories is the key to avoiding sticker shock.

Fees with Zero Tolerance

These costs cannot increase at all from what is quoted on your Loan Estimate, unless you request a change to your loan terms. Any increase must be covered by the lender. This category provides the most protection for you as a borrower.

Fees with a 10% Cumulative Tolerance

This category includes third-party services that your lender requires and for which you use a provider from the lender’s approved list. The total cost of all fees in this group cannot increase by more than 10% from the LE to the final Closing Disclosure.

A person reviewing a loan estimate document at a desk.

For example, if the LE estimated a combined $2,500 for title services and recording fees, the final amount on your Closing Disclosure for these specific services cannot exceed $2,750 ($2,500 + 10%).

Fees with No Tolerance Limit

These are costs that can change without any legal limit. This is often where homebuyers see the largest discrepancies, as they depend on choices you make or on factors outside the lender's control.

Understanding Your Escrow Account Calculation

An escrow account, also called an impound account, is a savings account managed by your lender to pay your property taxes and homeowners insurance on your behalf. At closing, you must fund this account with several months' worth of these payments upfront, which significantly adds to your cash-to-close.

Calculating Property Taxes

Your lender’s initial estimate for property taxes is often based on the seller's current tax bill. However, after the sale, the local authority, like the Harris County Appraisal District, will reassess the home's value, often at the higher sales price. This leads to a higher tax bill.

Calculating Homeowners Insurance

Lenders provide a general estimate for homeowners insurance on the LE, but the final premium depends entirely on the policy you choose. Factors like coverage limits, deductible amount, and even your credit score can dramatically alter the cost. Shopping for insurance early is the best way to get an accurate figure.

Lenders are also legally allowed to collect a cushion of up to two months of total escrow payments (taxes and insurance) to guard against unexpected increases. This adds to your initial deposit. (The data, information, or policy mentioned here may vary over time.)

The Critical Role of Your Interest Rate Lock

Your interest rate is not guaranteed until you formally 'lock' it with your lender. An unlocked rate is a 'floating' rate, subject to daily market fluctuations. If you receive an LE but delay locking the rate, and market rates rise, your final interest rate will be higher.

This has two major impacts:

  1. Higher Monthly Payment: A higher rate directly increases your principal and interest payment for the life of the loan.
  2. Increased Closing Costs: A higher rate means a larger daily interest charge, which increases the prepaid interest you owe at closing.

A rate lock secures your interest rate for a set period, typically 30 to 60 days. If your closing is delayed beyond this period for reasons within your control, you may have to pay a fee to extend the lock or accept the new, potentially higher, market rate.

Lender Fees vs. Third-Party Fees: Know the Difference

Clearly distinguishing between who you are paying is essential for understanding your closing costs. The fees are broken down into two primary types.

Fixed Lender Fees

These are the charges for the lender's services in creating and managing your loan. They are non-negotiable once quoted on the LE and fall under the 'zero tolerance' rule.

Variable Third-Party Fees

These fees are for services provided by other companies, not your lender. Your lender coordinates these services, but the cost can vary. These typically fall into the 10% or unlimited tolerance categories.

How to Challenge a Fee on Your Closing Disclosure

You have the right to question every single charge. At least three business days before your closing date, you will receive your final Closing Disclosure (CD). This is your last chance to catch errors.

Close-up of a Closing Disclosure document with key figures highlighted.
  1. Compare Line by Line: Sit down with your most recent Loan Estimate and your Closing Disclosure. Go through each fee, one by one.
  2. Identify Discrepancies: Note any fee that has increased. Check which tolerance category it falls into. Did a lender fee increase? That's a red flag. Did the sum of your 10% tolerance fees increase by more than 10%?
  3. Contact Your Loan Officer Immediately: For a home in The Woodlands, if you see the title fee jumped by 15%, call or email your loan officer right away. Do not wait until closing day.
  4. Request an Explanation and Correction: Ask for a clear, written explanation for the increase. If it's a violation of the tolerance rules, demand that the lender issue a credit to cover the difference. A legitimate 'changed circumstance', such as a change in your loan amount or a low appraisal, is one of the few reasons a zero-tolerance fee can be revised.

Decoding Prepaid Interest on Your Closing Statement

Prepaid interest often confuses buyers. It is not your first mortgage payment. It is the interest that accumulates on your loan from the day you close through the last day of that month. Your first full mortgage payment will be due on the first of the following month.

The calculation is straightforward: (Loan Amount x Interest Rate) / 365 = Daily Interest Cost Daily Interest Cost x Number of Days Remaining in the Month = Total Prepaid Interest Due at Closing

Closing later in the month reduces your prepaid interest charge but does not change the total interest paid over the life of the loan.

Common Junk Fees to Spot on Texas Loan Estimates

While most lenders are transparent, some may try to pad their profits with duplicative or unnecessary charges known as 'junk fees'. Always question fees that seem redundant.

Never be afraid to ask, 'What is this fee for, and is it negotiable?'. A good lender will provide clear answers.

Navigating the numbers on your Loan Estimate is the first step to a confident home purchase. If you're ready for a transparent mortgage process without surprises, our strategists can help you secure a fair deal. Apply now to get started with a team you can trust.

Author Bio

David Ghazaryan is the expert mortgage strategist and founder behind iQRATE Mortgages. With a mission to fund home loans that traditional banks won't touch, David specializes in helping clients with unique financial situations, including those recovering from foreclosure or bankruptcy. He expertly crafts smart, strategic, and stress-free mortgages by leveraging a vast network of over 100 lenders to secure competitive rates for investors and homebuyers alike. Praised for exceptional customer service, David has helped hundreds of families with a 97% satisfaction rate, guiding them to the mortgage they deserve.

References

CFPB - Understanding the Loan Estimate

CFPB - Your Home Loan Toolkit

HUD - Real Estate Settlement Procedures Act (RESPA)

FAQ

Which closing costs on my Loan Estimate are not allowed to change?
What is the 10% cumulative tolerance rule for closing costs?
Which fees on a Loan Estimate can increase without any limit?
How does failing to lock my interest rate affect my closing costs?
What is the difference between lender fees and third-party fees?
Why are the estimated property tax and insurance payments often different from the final amount?
What should I do if I find a fee that seems incorrect on my Closing Disclosure?
David Ghazaryan
David Ghazaryan

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