CONSUMER FINANCIAL PROTECTION BUREAU | OCTOBER 2020

How Mortgages Change 

Before Origination

The CFPB Office of Research
1 CONSUMER FINANCIAL PROTECTION BUREAU

This is another in an occasional series of publications from the Consumer Financial Protection 

Bureau’s Office of Research. These publications are intended to further the Bureau’s objective of 

providing an evidence-based perspective on consumer financial markets, consumer behavior, 

and regulations to inform the public discourse. See 12 U.S.C. §5493(b).1

 

1 Th is r eport was prepared by Du stin Beckett, Br ian Bu cks, Nicholas Li, and Ev a Nagypal.
2 CONSUMER FINANCIAL PROTECTION BUREAU

Table of contents

Table of contents..............................................................................................................2

1. Introduction ................................................................................................................3

2. Background and data................................................................................................6

2.1 The TRID Rule........................................................................................... 6

2.2 Data ............................................................................................................ 8

3. Timing of disclosure forms in mortgage origination .........................................11

4. Disclosure form counts ..........................................................................................16

5. Changes in mortgage terms...................................................................................20

6. Mortgage changes after consummation ..............................................................27

7. Conclusion................................................................................................................31
3 CONSUMER FINANCIAL PROTECTION BUREAU

1. Introduction

The terms and costs of mortgage loans (mortgages) can change during the origination process. 

This fact has long been recognized. For instance, Federal disclosure laws evolved to require 

disclosure forms be provided to consumers both when they apply for mortgages and before they 

consummate their mortgages. However, little is known about the nature of changes during the 

mortgage origination process. How mortgages change, by how much, and when are all 

important because consumers rely on disclosure forms to comparison shop among lenders and

service providers, and to understand the terms and costs of their mortgages. Significant 

changes in mortgage terms or costs from those that are initially disclosed can make it difficult 

for consumers to make informed mortgage choices.

This Data Point provides new information about the types of changes that occur during the 

mortgage origination process, their size and prevalence, and when they (and other mortgage 

milestones) occur in the mortgage origination process. This information is taken from a dataset 

of disclosure forms from roughly 50,000 mortgages originated between March 2016 and 

November 2017. Because lenders are required to provide new disclosure forms to consumers 

when mortgages change in certain ways, this analysis provides a window into how mortgages 

change and when these changes are disclosed to consumers.2 

This Data Point is being released at the same time as a Bureau report assessing the “Integrated 

Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the 

Truth in Lending Act (Regulation Z)” Rule (TRID Rule). The TRID Rule updated howFederal 

laws governing mortgage disclosure forms were implemented, including by combining 

previously separate and overlapping disclosure forms. The primary data source used in this 

Data Point contains mortgages originated after the TRID Rule took effect and so cannot speak 

to how the TRID Rule may have changed the size, prevalence, and timing of changes in 

mortgage terms. However, when possible, this Data Point reports data from other sources that 

allow for comparisons before and after the TRID Rule took effect. These data include responses 

to mortgage industry surveys fielded as part of the Bureau’s assessment of the TRID Rule.3

 

2 Len ders may also g ive the consumer a revised disclosure form ev en when it is not required by law, out of courtesy or 

cu stom. Disclosure form provision is discussed further in Section 2: Background and data. See Bureau of Con sumer 

Fin . Prot., Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and 

the Truth in Lending Act (Regulation Z) Rule Assessment (Oct. 1, 2020), https://www.consumerfinance.gov /datar esearch/research-reports/trid-rule-assessment. 

3 Id.
4 CONSUMER FINANCIAL PROTECTION BUREAU

Key findings include:

 Almost 90 percent of mortgages received at least one revision(either a revised Loan 

Estimate or a correctedClosingDisclosure). About 62 percent received at least one revised 

Loan Estimate, and about 49 percent received at least one corrected Closing Disclosure.

 The prevalence of changes in loan termsbetween the first Loan Estimate and the last Closing 

Disclosure varied greatly across mortgage terms tracked in Bureau data. For example, the 

annual percentage rate (APR)4 changed for more than 40 percent of mortgages, the loan 

amount and the loan-to-value (LTV)5 ratio changed for almost a quarter of mortgages, and 

the interest rate changed for about eight percent. In contrast, changes to maturity, loan type 

(conventional, Veterans Affairs (VA), Federal Housing Administration (FHA), United States

Department of Agriculture (USDA),6 rate type (fixed or adjustable-rate), and loan purpose 

(purchase, refinance, etc.) were relatively rare.

 Similarly, the magnitude of changes varied widely among the mortgage terms tracked in the 

Bureau data. Changes to loan amount and APR were relatively small, whereas many 

changes to interest rate and LTV ratio were relatively large. The disparity between the 

magnitude of changes in APR and interest rate are at least partly mechanical—APR would 

likely change slightly in response to small changes in loan amount or closing costs. 

 According to survey data, the disparitiesbetween the prevalence and magnitudes of changes 

to APR and changes to interest rate may also be due to precautions lenders took to avoid 

tolerance violations. More than three-quarters of respondents said their institution 

“sometimes,” “often,” or “almost always” estimated fees at the top of their range to avoid 

possible tolerance violations. The use of this strategy would imply that mortgage costs on 

the Closing Disclosure would often be lower than initial estimates, and these changes would 

subsequently show up in the Bureau’s data as a small decrease in APR.

 The median number of days between application and consumers receiving their first Loan 

Estimate was one calendar day. Thus, for most mortgages, lenders provided Loan Estimates 

sooner than they were required to under the TRID Rule.

 

4 A n APR is a broader measure of the cost of borrowing money than the interest rate. The A PR r eflects the interest 

r a te, any points, mortgage broker fees, and other charges that the borrower pays to get the loan. For that r eason, the

A PR is u sually h igher than the interest rate on a mortgage. See Bureau of Consumer Fin. Prot., What is the difference 

betw een a m ortgage interest rate and an APR? (Updated Nov . 15, 2019), https://www.consumerfinance.gov /askcfpb/what-is-the-difference-between-a-mortgage-interest-rate-and-an-apr-en-135/. 

5 Th e LTV ratio is a measure comparing the amount of a borrower’s mortgage with the a ppraised value of the 

pr operty. The h igher the borrower’s down payment, the lower the LTV ratio.

6 A conventional mortgage or conventional loan is a home buyer’s loan that is not offered or secured by a gov ernment 

en tity. It is available through or guaranteed by a private lender or the two gov ernment-sponsored enterprises—

Fa n nie Ma e and Freddie Ma c. A VA loan is a mortgage offered through a Department of V eterans Affairs program. A 

FHA loan is a mortgage that is insured by the Federal Housing Administration (FHA) and issued by an FHA-approv ed 

len der. A USDA loan is a mortgage guaranteed or issued by the USA or a pprov ed lender to rural and suburban 

bor r owers.
5 CONSUMER FINANCIAL PROTECTION BUREAU

 The median number of days between consumers receiving their first Closing Disclosure and 

closing on their mortgage was six calendar days. Thus, for most mortgages, lenders 

provided Closing Disclosures sooner than they were required to under the TRIDRule.

 The time between applying for and closing on a mortgage varied significantly. The median 

number of days between application and closing was 44 calendar days, and for half of 

mortgages, this duration was between 35 and 57 days (the 25th and 75th percentiles). 

 Almost half of the mortgages had at least one post-closingClosing Disclosure, which is a 

corrected Closing Disclosure that is generated after a mortgage is consummated. The 

finance charge and APR changed between the last Closing Disclosure and the last postclosingClosing Disclosure for only about one percent of mortgages with a post-closing

Closing Disclosure, and changes to other loan terms were even rarer. This underscores the 

fact that many post-closingClosing Disclosures are generated in response to secondary 

market requirements and do not necessarily reflect substantial changes to the mortgage. 

This Data Point is organized as follows. Section 2 provides background. Section 2.1 describes 

relevant provisions of the TRID Rule, including when disclosures must be provided and the 

details around when terms and costs are allowed to change. Section2.2 describes the data 

analyzed in this Data Point. Sections 3 through 5 report on disclosure form timing, disclosure 

form counts, and the prevalence and magnitude of changes in certain mortgage terms, 

respectively. Finally, Section 6 describes data on Closing Disclosures provided after closing and 

Section 7 provides this Data Point’s conclusion. 
6 CONSUMER FINANCIAL PROTECTION BUREAU

2. Background and data

2.1 The TRID Rule

In November 2013, the Bureau issued a final rule titled “Integrated Mortgage Disclosures Under 

the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act 

(Regulation Z)” 7 to implement sections 1098 and 1100A of the Dodd-Frank Wall Street Reform 

and Consumer Protection Act (Dodd-Frank Act) as well as certain other new provisions enacted 

in the Dodd-Frank Act.8 The Bureau amended the 2013 final rule on two occasions before its 

effective date, and the amended rule took effect on October 3, 2015.9 This Data Point refers to 

the rule as amended when it took effect on October 3, 2015, as the “TRID Rule”. The Bureau 

subsequently amended the TRID Rule in July 2017 and April 2018.10 The July 2017 

Amendments took effect on October 10, 2017,1 1 and the April 2018 Amendments took effect on 

June 1, 2018. 1 2 

Before the TRID Rule, Federal law generally required that consumers applying for mortgages get 

two different forms: one with disclosures regarding the cost of credit and another concerning 

real estate settlement costs. Shortly before closing on the loan, consumers received two 

additional forms; again, one regarding the cost of credit and another concerning real estate 

settlement costs. These disclosure forms were required by two distinct federal statutes, the 

Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). Prior to 

the Bureau’s creation, two federal agencies, the Board of Governors of the Federal Reserve 

System (Board) and the U.S. Department of Housing and Urban Development (HUD), 

developed and oversaw these disclosures.

 

7 7 8 Fed. Reg. 7 9730. (Dec. 31, 2013). 

8 Th e contents of this subsection are largely transcribed from the TRID Rule assessment r eport. For more 

in formation about the TRID Ru le, see Bureau of Con sumer Fin. Prot., Integrated Mortgage Disclosures Under the 

Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) Rule Assessment

(Oct. 1, 2020), https://www.consumerfinance.gov /data-research/research-reports/trid-rule-assessment. 

9 See 80 Fed. Reg. 8767 (Feb. 19, 2015); 80 Fed. Reg. 43911 (July 24, 2015). 

1 0 See 82 Fed. Reg. 37656 (Aug. 11, 2017); 83 Fed. Reg. 19159 (May 2, 2018).

1 1 Id. Th e July 2017 Amendments were effective Oct. 10, 2017, but the July 2017 Amendments had an optional 

com pliance period in effect until Oct. 1, 2018. 82 Fed. Reg. 37656, 37762-65. (Aug. 11, 2017). 

1 2 8 3 Fed. Reg. 19159. (May 2, 2018). 
7 CONSUMER FINANCIAL PROTECTION BUREAU

The TRID Rule combined these two sets of forms into a single set of forms. The TRID Rule 

generally requires that both a Loan Estimate and Closing Disclosure be provided for closed-end 

consumer credit transactions secured by real property or a cooperative unit. 1 3 HomeEquity 

Lines of Credit are not subject to the TRID Rule, nor are chattel-dwelling loans. In addition, the 

TRID Rule specifically exempts reverse mortgages. 

The TRID Rule requires the creditor or mortgage broker to give the Loan Estimate to the 

consumer within three business days after the consumer applies for a mortgage. 1 4 The TRID 

Rule defines an “application” for these purposes, namely, the consumer’s name, income, social 

security number to obtain a credit report, the property address, an estimate of the value of the 

property, and the mortgage amount sought. 1 5 

The TRID Rule generally requires that the creditor ensure the consumer receives the Closing 

Disclosure no later than three business days before consummation.

1 6 To prevent closing delays, 

the TRID Rule allows creditors to update Closing Disclosures in certain circumstances without 

triggering an additional three-business-day waiting period. 1 7 A corrected Closing Disclosure 

must be issued with a new three-business-day review period if, between the time the Closing 

Disclosure is first provided and consummation, the loan’s APR becomes inaccurate (beyondthe 

specified tolerance level), the loan product changes, or a prepayment penalty is added. 1 8 All 

other changes to the Closing Disclosure may be made without an additional three-business-day 

review period, but a corrected Closing Disclosure must be provided at or before loan closing. 1 9

 

1 3 1 2 C.F.R. § 1 026.19(e)(1)(i) and (f)(1)(i).

1 4 See 12 C.F.R. § 1 026.19(e)(1)(iii).

1 5 See 12 C.F.R. § 1 026.2(a)(3). Consistent with prior r equirements, the creditor generally cannot impose any fees on 

a con sumer in connection with a consumer’s application (other than a fee for obtaining the consumer’s credit report) 

u n til after the consumer has received the Loan Estimate and the consumer has indicated an intent to proceed with the 

tr ansaction. See C.F.R. § 1 026.19(e)(2)(i).

1 6 See 12 C.F.R. § 1 026.19(f)(1)(ii). TILA, a s implemented by Regulation Z, g enerally prov ides that, if the early TILA 

disclosures (TIL) contain an APR that becomes inaccurate, the creditor shall furnish corrected TILA disclosures so 

th at they are received by the consumer not later than three business days before consummation. On the other hand, 

RESPA a nd Regulation X g enerally r equire that the RESPA settlement statement be prov ided to the borrower a t or 

befor e settlement.

1 7 See 12 C.F.R. § 1 026.19(f)(2)(i).

1 8 1 2 C.F.R. § 1 026.19(f)(2)(ii).

1 9 1 2 C.F.R. § 1 026.19(f)(2). Closing and consummation are separate ev ents but generally occur around the same 

time. “ Consummation” is when the consumer becomes contractually obligated to the creditor on the loan. The 

definition of “closing” varies by state, but roughly speaking, is the process through which deeds are conveyed, 

r ecorded, and transacted (when applicable), funds are exchanged (or placed in the settlement agent’s possession), and 
8 CONSUMER FINANCIAL PROTECTION BUREAU

The TRID Rule also changed the tolerance rules that limit creditors and third-party service 

providers from charging consumers settlement costs that exceed the estimates that had been 

previously disclosed. Prior to the TRID Rule, HUD amended Regulation X in 2008 to require 

disclosing estimated settlement costs on the Good Faith Estimate (GFE) formand established 

tolerances for suchamounts.20 The GFE tolerance rules generally place charges into three 

categories: (1) the creditor’s charges for its own services, which cannot exceed the creditor's 

estimates unless an exception applies (zero tolerance); (2) charges for settlement services 

provided by third parties, which cannot exceed estimated amounts by more than ten percent 

unless an exception applies (ten percent tolerance); and (3) other charges that are not subject to 

any limitation on increases (no tolerance limit).21 

The TRID Rule subjects a larger category of charges to a zero tolerance prohibition on cost 

increases than was the case previously under RESPA. Specifically, the TRID Rule expands the 

zero tolerance category to also include fees charged by affiliates of creditors, fees charged by 

service providers selected by the creditor, and fees for services for which the creditor does not 

permit consumers to shop. However, if there is a valid justification for the cost increase, such as 

if the consumer asks for a change, the consumer chooses a service provider that was not 

identified by the creditor, or the informationprovided at application was inaccurate or becomes 

inaccurate, the creditor can reset the tolerance limits by providing a revised Loan Estimate or a 

Closing Disclosure with the updated costs within three business days.22 Additionally, the TRID 

Rule retains Regulation X’s provisions which allow creditors to cure tolerance violations through 

providing a refund to the consumer, of the amount by which the tolerance was exceeded, at or 

within 30 days of closing.23

2.2 Data

Analyses in this Data Point rely primarily on de-identified mortgage disclosure form data 

obtained through the Bureau’s supervisory activities. When possible and relevant, to provide 

some insight into how practices may nowdiffer from before the TRID Rule, the discussion 

 

th e legal obligations of the parties (buyer/consumer, seller (if applicable), r eal estate agent, creditor, lienholders, and 

th ird-party service prov iders) are resolved.

20 7 3 Fed. Reg. 68203 (Nov. 17, 2008). See also 12 C.F.R. § 1024.7. This Regulation X prov ision continues to apply 

w ith respect to certain mortgages not subject to the TRID Ru le.

21 1 2 C.F.R. § 1 024.7(e).

22 See 12 C.F.R. § 1 026.19(e)(3) and (4).

23 Wh ereas Regulation X allows creditors to cure tolerance violations by prov iding the refund 30 days a fter 

settlement, for tolerance v iolations under the TRID Ru le the cure period was lengthened to 60 days a fter 

con summation. 12 C.F.R. § 1 024.7(i); 12 C.F.R. § 1 026.19(f)(2)(v).
9 CONSUMER FINANCIAL PROTECTION BUREAU

draws on data from the Bureau’s assessment of the TRID Rule and summary statistics both 

before and after the TRID Rule provided to the Bureau by a provider of loan origination systems.

2.2.1 CFPB Compliance Tool Data

The Bureau’s examiners used software (Compliance Tool) to collect data directly from 

supervised entities. The Compliance Tool processed a sample of loan files during an exam to 

check for compliance, keeping certain selecteddata fields for analysis. The Compliance Tool 

assisted examiners as they checked for compliance withTILA, RESPA, and the TRID Rule, 

among other statutes and regulations. The information the tool collectedincludes borrower and 

loan characteristics and informationabout disclosuresprovided to borrowers. 

This Data Point analyzes a sample of exam data collected by the Compliance Tool. The sample 

includes data from mortgage disclosure forms for over 50,000 mortgages consummated 

between March 2016 and November 2017.

The analysis of these data comes with several caveats. First, the data were only collected for 

mortgages originated after the TRID Rule took effect and therefore they cannot be used to infer 

the effects of the TRID Rule. Second, the included mortgages were selected based on data 

quality and completeness considerations—these data therefore are not representative of all 

mortgages or even of all mortgages examined by the Bureau.24

2.2.2 Industry Survey Data

In January 2020, the Bureau conducted three surveys of mortgage industry participants: a 

survey of mortgage lenders, a survey of mortgage loan officers, and a survey of companies that 

conduct real-estate closings. These surveys were created to supplement the Bureau’s 

assessment of the effectiveness of the TRID Rule by collecting data and information on the 

experiences of industry participants before, during, and after the TRID Rule’s effective date.25 

Eligible individualswere generally those in their role in the mortgage market both at the time of 

the survey andbefore the TRID Rule took effect.

 

24 For ex ample, due to divergent information technology solutions employ ed, different examined entities prov ided 

m or e or less complete set of disclosures for mortgages they originated, and this influenced whether their data were 

in cluded in the current analysis.

25 Bu r eau of Consumer Fin. Prot., Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act 

(Reg ulation X) and the Truth in Lending Act (Regulation Z) Rule Assessment (Oct. 1, 2020), 

h ttps://www.consumerfinance.gov /data-research/research-reports/trid-rule-assessment. 
10 CONSUMER FINANCIAL PROTECTION BUREAU

The surveys were distributed online betweenJanuary 22, 2020 andMarch 13, 2020. The 

Bureau received over 1,000 responses across all three surveys. Survey data reported here 

include only responses from respondents who completed at least 65 percent of the questions in 

their survey.26

The survey data have two potential limitations, however. First, the data were collected in 2020,

and so estimates of practices or behaviors prior to the TRID Rule’s effective date likely relied on

respondents’ recollectionof facts at least four and a half years in the past. These data may 

therefore be inaccurate due to recall errors. Second, responses are not likely to be

representative of all lenders, loan officers, or closing companies because the surveys were 

voluntary. 

2.2.3 Summary statistics from a mortgage service provider

A mortgage service provider voluntarily provided the Bureau data generated by its loan 

origination system. These data include summary statistics of mortgages originated between 

2013 and 2019 on the number of disclosure forms generated per mortgage both before and after

the TRIDRule’s effective date. 

 

26 For m ore information a bout the TRID a ssessment industry surveys, see Bureau of Consumer Fin. Prot., In tegrated 

Mor tgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act 

(Reg ulation Z) Rule Assessment, Appendix D (Oct. 1, 2020), https://www.consumerfinance.gov/datar esearch/research-reports/trid-rule-assessment. 
11 CONSUMER FINANCIAL PROTECTION BUREAU

3. Timing of disclosure forms in 

mortgage origination

The process of getting a mortgage may involve several steps including shopping for and taking 

out a mortgage, shopping for settlement services, andpurchasing a home (unless the borrower 

is refinancing). The sooner disclosure forms are provided to consumers, the sooner they can 

understand the terms and costs of their mortgage offer, negotiate these terms or costs, or use the 

disclosures to shop for other offers or settlement services. This section first describes the timing 

of TRID disclosure forms in the Compliance Tool data and breaks down the timing of different 

stages in the process. It then presents data from the TRID Assessment survey of Loan Officers 

(Loan Officer Survey) and the TRID Assessment survey of Closing Companies (Closing Company 

Survey) to compare timing before and after the TRID Rule took effect. 

TABLE 1: VARIOUS PERCENTILES OF NUMBER OF DAYS BETWEEN MILESTONES AND DELIVERY OF 

DISCLOSURE FORMS

Percentile App to 

First LE

App to 

Closing

First LE

to 

Last LE*

First LE

to 

Last CD

First CD

to 

Last CD*

First CD 

to 

Closing

Last CD

to

Closing

10th 0 29 4 21 1 1 0 

25th 1 35 11 29 3 4 1 

50th 1 44 22 38 5 6 3 

75th 3 57 36 52 8 8 5 

90th 5 75 55 70 14 13 8 

* Da ta presented in column “ First LE to La st LE” exclude mortgages that received only on e Loan Estimate (37.9

per cent of all mortgages), and data presented in column “ First CD to Last CD” exclude mortgages that received only 

on e Closing Disclosure (51.2 percent of a ll mortgages).
12 CONSUMER FINANCIAL PROTECTION BUREAU

Table 1 displays percentiles of the number of calendar days in the Compliance Tooldata between 

various milestones in the origination process.27 The milestones include the issuance of the first 

and last Loan Estimates (LE), the issuance of the first and last Closing Disclosures (CD), the 

loan application date (App), and the loan consummation date (Closing). The median number of 

days between the first Loan Estimate and the last Closing Disclosure was 38 days, and the 

median duration between application and closing was 44 days. Half of mortgages went from 

application to closing in about one or two months (the interquartile range was 35 to 57 days); 

ten percent of mortgages took more than about 2.5 months (the 90th percentile was 75 days).

The mortgage origination process moved reasonably quickly for the median borrower at each 

stage. However, there was also great variability in many stages. The process for mortgages that 

require multiple Loan Estimates can be particularly protracted; roughly a quarter received Loan 

Estimates over the course of more than a month (the upper quartile was 36 days). The stages of 

Closing Disclosure provision moved relatively quickly withclosing usually coming within a week 

of the first Closing Disclosure. 

TABLE 2: PERCENTAGE DISTRIBUTION OF AVERAGE NUMBER OF DAYS BETWEEN THE PROVISION OF 

THE FIRST HUD-1 AND CLOSING 

Average number of days Share (percent)

Zero business days 20.0 

One business day before 43.5

Two business days before 20.9 

Three or more business days before 11.3

Did not respond 4.4

Sample size 115

 

27 Th e table displays calendar days rather than business days. The TRID Ru le’s timing requirements are generally 

specified in terms of business days. This analysis uses calendar days, as opposed to business days, to measure 

differences between dates of v arious events since a non-negligible number of ev ents fall on weekends and holidays. 

A lso, calendar days may constitute the natural unit of time for consumers.
13 CONSUMER FINANCIAL PROTECTION BUREAU

Table 2 displays responses to a question from the Closing Company Survey that asked 

respondents to recall, how many days before closing they gave borrowers the first HUD-1 

settlement statement (HUD-1), in the 12 months before the TRID Rule.28 About 20 percent 

responded that they provided the HUD-1 on the same day as closing, on average, while only 

about 11 percent responded that they provided the HUD-1 three or more business days before 

closing. In contrast, after the TRID Rule took effect, all lenders were required to provide the 

first Closing Disclosure at least three business days before consummation.29

TABLE 3: PERCENTAGE DISTRIBUTION OF AVERAGE NUMBER OF DAYS BETWEEN PROVISION OF THE 

LAST CLOSING DISCLOSURE AND CONSUMMATION

Average number of days Share (percent)

Zero business days 12.0

One business day before 22.8

Two business days before 13.6 

Three or more business days before 36.4

I don’t know 8.7

Did not respond 6.5

Sample size 184

 

28 See Bu reau of Consumer Fin. Pr ot., Integrated Mor tgage Disclosures Under the Real Estate Settlement Procedures 

A ct (Regulation X) and the Truth in Lending A ct (Regulation Z) Rule A ssessment, A ppendix D, TRID A ssessment 

Su rvey of Closing Companies, qu estion 12 (Oct. 1, 2020), https://www.consumerfinance.gov/data-research/researchr eports/trid-rule-assessment. 

29 7 8 Fed. Reg. 7 9730, 80086. (Dec. 31, 2013). TILA, a s implemented by Regulation Z, g enerally prov ides that, if the 

ea r ly Truth in Lending (TIL) disclosures contain an A PR that becomes inaccurate, the creditor shall furnish corrected 

TIL disclosures so that they are received by the consumer not later than three business days before consummation. 

On the other hand, RESPA and Regulation X generally require that the RESPA settlement statement be provided to 

th e borrower at or before settlement. To prevent unnecessary closing delays, the initial Closing Disclosure may 

in clude estimates based on the best information reasonably available to the creditor. Various changes to the Closing 

Disclosure are permitted without an additional three-business-day waiting period. If, between the time the Closing 

Disclosure is first prov ided and consummation, the loan's A PR becomes inaccurate (over and above the specified 

tolerance level), the loan product changes, or a prepayment penalty is a dded, a corrected Closing Disclosure must be 

issu ed with an a dditional three-business-day period to review the transaction. A ll other changes to the Closing 

Disclosure may be made without an additional three-business-day waiting period, but a corrected Closing Disclosure 

m ust be prov ided at or before consummation.
14 CONSUMER FINANCIAL PROTECTION BUREAU

Table 3 displays responses to a question from the Loan Officer Survey that asked respondents 

how many days before consummation they gave borrowers a Closing Disclosure that reflected 

the mortgage’s final terms and costs in 2018.30 About 12 percent of respondents reported giving 

consumers this disclosure on the same day as consummation, and slightly more than a third 

indicated they provided the final Closing Disclosure three or more business days in advance.

TABLE 4: PERCENTAGE DISTRIBUTION OF AVERAGE NUMBER OF DAYS BETWEEN FIRST CONTACT 

AND PROVISION OF INITIAL DISCLOSURE

Average number of days First Good Faith 

Estimate

First Loan 

Estimate

Less than one day 3.3 2.2 

One day 21.7 20.7 

Two days 27.2 26.1 

3 – 4 days 22.3 25.5

5 – 10 days 12.0 13.0

Greater than 10 days 7.6 6.0

Did not respond 6.0 6.5

Sample size 184 184

The TRID Rule changed the definition of a mortgage “application” to remove the ‘‘catch-all’’ 

element that was in the previous definition. The Bureau believed that removing that element 

would enable consumers to get the Loan Estimate earlier. 31 Table 4 displays responses to the 

Loan Officer Survey questions about how many days typically passed after the lender and 

consumer first came into contact before the lender provided the first disclosure, both before and 

 

30 See Bu reau of Consumer Fin. Pr ot., Integrated Mor tgage Disclosures Under the Real Estate Settlement Procedures 

A ct (Regulation X) and the Truth in Lending A ct (Regulation Z) Rule A ssessment, A ppendix D TRID A ssessment 

Su rvey of Loan Officers, qu estion 12 (Oct. 1, 2020), https://www.consumerfinance.gov /data-research/researchr eports/trid-rule-assessment. 

31 7 8 Fed. Reg. 7 9730, 79762 (Dec. 31, 2013).
15 CONSUMER FINANCIAL PROTECTION BUREAU

after the TRIDRule took effect.32 The Bureau cannot know howloan officers would have 

respondedto this survey were it not for the TRID Rule, and, as noted above,the results may not 

be representative of all lenders and rely on respondents’ recall of their practices several years 

earlier. With these caveats, the responses do not suggest that consumers generally received 

Loan Estimates any sooner after the first contact than consumers had previously received 

GFEs.33

 

32 See Bu reau of Consumer Fin. Pr ot., Integrated Mor tgage Disclosures Under the Real Estate Settlement Procedures 

A ct (Regulation X) and the Truth in Lending A ct (Regulation Z) Rule A ssessment, A ppendix D TRID A ssessment 

Su rvey of Loan Officers, qu estions 7 and 8 (Oct. 1, 2020), https://www.consumerfinance.gov/data-research/researchr eports/trid-rule-assessment. 

33 In con trast, in response to the Bureau’s Nov ember 2019 Request for In formation (Nov ember 2019 RFI), a group of

con sumer adv ocates stated that the definition of “ application” under the TRID Ru le promotes earlier r eceipt of Loan 

Estimates. See Bureau of Consumer Fin. Prot., Integrated Mortgage Disclosures Under the Real Estate Settlement 

Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) Rule Assessment, Appendix B: Comment 

su mmary (Oct. 1, 2020), https://www.consumerfinance.gov/data-research/research-reports/trid-rule-assessment. 
16 CONSUMER FINANCIAL PROTECTION BUREAU

4. Counts of disclosure forms 

Every originated mortgage has at least one Loan Estimate and at least one Closing Disclosure. 

When there is a “change in circumstance” then the lender may provide an updated Loan 

Estimate or Closing Disclosure with new terms or costs that reflect the change in 

circumstance.34 Additionally, if mortgage terms change after the borrower receives a Closing 

Disclosure, then the borrower must be given an updated Closing Disclosure before

consummation.35 The Bureau also understands that, as a matter of courtesy, some lenders may 

also provide borrowers with updated Loan Estimates that reflect minor changes, even when 

updated forms are not required. Updated disclosures are intended to inform the borrower of 

changes in terms or costs (and also to update the tolerances of the mortgage, when appropriate). 

The number of disclosure forms that a consumer receives therefore may be a measure of both

the accuracy of the early disclosure forms and the number of changes a mortgage experiences 

over the course of the origination process. Fewer issued disclosures may suggest that a 

consumer’s mortgage didnot change much, and therefore their first Loan Estimate was a 

relatively accurate forecast of the final mortgage terms and costs. More disclosures may suggest 

that the borrower was more likely to have faced changes in loan costs and terms as they moved 

from application to closing. 

Table 5 shows the distribution of the number of Loan Estimates and Closing Disclosures that 

consumers received in the Compliance Tooldata. More thana third of consumers (37.9 percent) 

received only one Loan Estimate, which suggests that their loan terms did not change prior to 

the Closing Disclosure. Consumers most commonly received two Loan Estimates, and about 22 

percent received three or more. Close to half of consumers receive multiple Closing Disclosures. 

These reflect changes in loan terms in the last stage of the mortgage origination, though some of 

the multiple Closing Disclosuresmay have been pro forma.36 

 

34 A lender generally cannot change disclosed terms or costs beyond certain boundswithout a valid “changed 

cir cumstance.” See Section 2.1: The TRID Ru le.

35 1 2 C.F.R. § 1 026.19(f)(2)(i); comment19(f)(2)(i)-1 through -2. 

36 Th rough discussions with industry, the Bureau understands that it is common practice for a lender to prov ide a 

n ew Closing Disclosure at closing, ev en if the terms and costs have not changed. 
17 CONSUMER FINANCIAL PROTECTION BUREAU

TABLE 5: PERCENTAGE DISTRIBUTION OF NUMBER OF LOAN ESTIMATES (LE) AND CLOSING 

DISCLOSURES (CD) PROVIDED PER MORTGAGE 

Number of Forms

One Closing 

Disclosure

Two Closing 

Disclosures 

Three or

more Closing 

Disclosures 

Row total

One Loan Estimate 12.3 17.6 8.0 37.9

Two Loan Estimates 25.7 9.8 4.1 39.6

Three or more Loan Estimates 13.1 6.0 3.2 22.4

Column total 51.2 33.5 15.3 100.0

Table 6 displays responses to the Loan Officer Survey about the number of revised disclosure 

forms provided to consumers, on average.37 Althoughthe data are from different sources and of 

different types (survey compared to administrative data), the data are broadly consistent, with 

both data sources indicating that borrowers typically got one or two Loan Estimates and Closing 

Disclosures and, on average, were somewhat more likely to receive multiple Loan Estimates 

than multiple Closing Disclosures. 38

TABLE 6: PERCENTAGE DISTRIBUTION OF AVERAGE NUMBER OF REVISED DISCLOSURE FORMS 

PROVIDED PER MORTGAGE (AMONG THOSE WHO RESPONDED TO THE QUESTIONS)

Average number of forms

Revised Loan 

Estimates 

Revised Closing 

Disclosures 

Less than one per consumer 31.0 51.5 

Between one and two 42.9 37.6 

Between two and three 19.6 9.7 

 

37 See Bu reau of Consumer Fin. Pr ot., Integrated Mor tgage Disclosures Under the Real Estate Settlement Procedures 

A ct (Regulation X) and the Truth in Lending A ct (Regulation Z) Rule A ssessment, A ppendix B: Comment summary

TRID A ssessment Survey of Loa n Officers, qu estions 9 and 11 (Oct. 1, 2020), 

h ttps://www.consumerfinance.gov /data-research/research-reports/trid-rule-assessment. 

38 Th ese data r elate to revised disclosure forms, whereas the Compliance Tool data relate to total counts. Thus, in 

com paring counts of disclosures, the sources differ by one: for example, “less than one per consumer” in the Loan 

Officer Survey is comparable to between one a nd two disclosure forms in the Compliance Tool data. 
18 CONSUMER FINANCIAL PROTECTION BUREAU

Average number of forms

Revised Loan 

Estimates 

Revised Closing 

Disclosures 

More than three 6.5 1.2 

Sample size 168 165

The Loan Officer Survey also asked respondents to compare the number of revised Loan 

Estimates they issued to the number of revised GFEs they issued prior to the TRID Rule. Most 

respondents (55 percent) reported issuing more revised Loan Estimates (including a quarter 

who reportedissuing “significantly more” Loan Estimates), whereas less than six percent 

reported issuing fewer revised Loan Estimates. 39 

FIGURE 1: AVERAGE NUMBER OF FORMS GENERATED PER MORTGAGE BY TYPE OVER TIME

 

39 See Bu reau of Consumer Fin. Pr ot., Integrated Mor tgage Disclosures Under the Real Estate Settlement Procedures 

A ct (Regulation X) and the Truth in Lending A ct (Regulation Z) Rule A ssessment A ppendix D, TRID A ssessment 

Su rvey of Loan Officers, qu estion 10.f. (Oct. 1, 2020), https://www.consumerfinance.gov/data-research/researchr eports/trid-rule-assessment. 
19 CONSUMER FINANCIAL PROTECTION BUREAU

To further investigate how disclosure form counts may have changed after the TRID Rule, 

Figure 1 displays data from a mortgage software provider. These data contain the average 

number of Loan Estimates, Closing Disclosures, HUD-1 settlement statements, and TIL 

disclosuresper mortgage generated by the provider’s system over time. The data do not include

GFEs, and the counts of TILdisclosures include both early TILs and final TILs.

Averaging each series over time, about twice as many Closing Disclosures were generated than 

HUD-1 settlement statements, on average. However, the increase cannot be attributedto the 

TRID Rule shifting the likelihood that mortgage terms changed because other changes may have 

contributed to the provider’s systemto generatingmore Closing Disclosures thanHUD-1 

settlement statements. For example, when the provider changed their systems to accommodate 

the TRID Rule, they may have also changed other features that changed the number of 

disclosure forms generated by their system. Similarly, as lenders and their partners learned the 

new software and adopted new practices to comply with the TRID rule, they might have changed 

the number of disclosure forms they generated while using the system.40 

The mortgage software provider’s data also show that somewhat fewer Loan Estimates were 

generated than TIL forms, on average. This difference does not indicate, however, how the 

number of disclosures generated changed at this stage in the origination process (or, in turn, any 

shift in the likelihood of changes in mortgage terms) because the software provider’s data do not 

include GFEs, and the TIL disclosure data include both early and final TILs.

 

40 Com pared to the Compliance Tool data, these data show prov iders’ sy stem producing about 50 percent more Loan 

Estimates and about twice a s many Closing Disclosures which suggests the lenders’ practices often lead to more forms 

being g enerated than are prov ided to consumers (as r eported in the Compliance Tool data). Lenders’ practices may 

h av e changed in part to comply with the TRID Ru le. The change may also be due, in part, to sy stematic changes in 

h ow firms complied with TILA and RESPA. Pr ior to the TRID Rule, many settlement agents interpreted RESPA to 

r equ ire that the HUD-1 be made available to consumers, but that they were not required to provide a HUD-1 unless 

th e consumer requested it (7 8 Fed. Reg. 79730, 7 9799 (Dec. 31, 2013)). Thus, ev en if a consumer’s mortgage terms 

a n d costs changed after the HUD-1 was “available” to the consumer, the software prov ider’s sy stem may reasonably 

h av e r ecorded that only one HUD-1 was g enerated. In contrast, the TRID r ule requires lenders to prov ide a consumer 

w ith a copy of the Closing Disclosure prior to consummation. If a ny change is made to the mortgage after the initial 

Closing Disclosure is provided, then the lender must prov ide a corrected Closing Disclosure a t (or before) 

con summation (§ 1 026.19(f)(2)(i); Comment 19(f)(2)(i)-1 through -2 ).
20 CONSUMER FINANCIAL PROTECTION BUREAU

5. Changes in mortgage terms

Whether revisions of disclosure forms consequentially affect a consumer’s ability to shop for a 

mortgage or to be prepared for closing likely depends, in part, on the size of the changes in loan 

terms. This section first considers the frequency of changes to individual mortgage terms. It 

then considers the size and direction of changes to mortgage terms.

TABLE 7: PERCENTAGE FREQUENCY OF CHANGES BETWEEN DISCLOSURE FORMS BY LOAN TERM

Loan term

First Loan 

Estimate to 

Last Loan 

Estimate

Last Loan 

Estimate to 

First Closing 

Disclosure

First Closing 

Disclosure to 

Last Closing 

Disclosure

First Loan 

Estimate to 

Last Closing 

Disclosure

Annual percentage rate (APR) 20.6 36.0 4.2 40.2

Finance charge* -- -- 2.8 -- 

Loan amount 14.2 10.4 4.2 23.7

Loan-to-value ratio 12.2 14.4 4.0 23.9

Interest rate 7.5 1.0 0.3 8.2

Maturity term 0.6 0.1 0.03 0.8 

Loan type 0.2 0.004 0.002 0.2 

Rate type 0.2 0.1 0.2 0.5

Loan purpose 0.03 0.02 0 0.06 

* Fin ance charge is n ot reported on a Loan Estimate

Table 7 displays the percentage of mortgages in the Compliance Tool datawith changes in terms 

at stages between the first Loan Estimate and the last Closing Disclosure: the first Loan Estimate 

to the last Loan Estimate, the last Loan Estimate to the first Closing Disclosure, and the first 
21 CONSUMER FINANCIAL PROTECTION BUREAU

Closing Disclosure to the last Closing Disclosure.41 For example, the table shows that 20.6

percent of all mortgages experienced a change in APR between the first and last Loan Estimate, 

and, accordingly, 79.4 percent either received a single Loan Estimate or had no change in the 

APR between the first and last Loan Estimate. The last column gives the overall frequency of 

changes between the first Loan Estimate and the last Closing Disclosure. The sum of the 

frequencies from the three intermediate stages is an upper bound on the overall frequency in the 

last column, since the same mortgage can undergo changes in more than one stage. 

The term that changed most frequently for all four comparisons was APR, which changed 

between the first Loan Estimate and the last Closing Disclosure for about 40 percent of 

mortgages in the Compliance Tooldata.42 Changes in loan amount, loan-to-value (LTV) ratio, 

and interest rate were also relatively common. In contrast, changes to maturity term, loan type 

(conventional, insured by Federal Housing Administration, etc.), rate type (fixed or adjustablerate), and loan purpose (purchase, refinance, etc.) occurred for less than one percent of 

mortgages. 

Changes were more common between Loan Estimates than between Closing Disclosures—for 

almost all terms, more than three times as many mortgages had changes between Loan 

Estimates than between Closing Disclosures. Furthermore, as evidenced by the second column, 

many changes in APR, loan amount, and LTV ratio happened between the last Loan Estimate

and the first Closing Disclosure. The finance charge is a term that only appears on Closing 

Disclosures. It changed between Closing Disclosures for about three percent of mortgages.

 

41 For m ortgages with on ly one Loan Estimate, the first and last Loan Estimate are the same and thus there are n o 

ch anges by definition. Similarly, for mortgages with only on e Closing Disclosure, the first and last Closing Disclosure

a r e the same. 

42 Th is is natural since APR would change, by definition, in response to changes in sev eral of the terms tracked in 

Ta ble 7, including interest rate, loan amount, and maturity term. Changes to loan type, rate type, or loan purpose 

w ou ld also likely imply a change in A PR.
22 CONSUMER FINANCIAL PROTECTION BUREAU

FIGURE 2: DISTRIBUTION OF CHANGE IN NUMERICAL LOAN TERMS BETWEEN THE FIRST LOAN 

ESTIMA TE AND THE LAST CLOSING DISCLOSURE AMONG LOANS THAT HAD A CHANGE IN 

THE TERM

Whether frequent changes in mortgage terms are consequential depends on the direction and 

magnitude of those changes. Figure 2 plots histograms of mortgage term changes from the first 

Loan Estimate to the last Closing Disclosure among loans with a change.43 For eachterm, a 

histogram reports the frequencies of changes to that termof different sizes. For example, the 

first panel shows that about 35 percent of changes to mortgages’ loan amounts were increases

between zero and 2.5 percent of the original loan amount, while about 27 percent of changes 

were decreases between 0 and 2.5 percent of the original loan amount. Most changes in the 

loan amount were small, with about 80 percent of changes within five percent of the initial 

amount. Changes in LTV ratio were mixed: about half of changes in the LTV ratio were less than 

five percent of the original ratio, but more than 25 percent of changes were greater than 10 

percent of the original ratio. Changes in the interest rate were often substantial—the median 

 

43 Histograms are prov ided for terms that are numerical. Categorical terms such a s loan type are n ot pictured.
23 CONSUMER FINANCIAL PROTECTION BUREAU

absolute change was 25 basis points. Changes in APR tended to be smaller, as close to 90

percent of changes were less than 20 basis points.

Looking at changes between Loan Estimates in particular, Figure 3 plots the distribution of 

changes of numeric loan terms between the first and last Loan Estimate among loans with a 

change. In the top left panel, nearly 55 percent of changes in loan amount were smaller than 2.5 

percent, but 12 percent of changes were larger than 10 percent in absolute value. In the top right 

panel, changes in the LTV ratio were smaller than 2.5 percent in around 35 percent of cases, but 

larger than 10 percent in absolute value for about 25 percent of cases. In the bottom left panel, 

more than 80 percent of changes in the interest rate were less than 50 basis points in absolute 

value. Finally, in the bottom right panel, changes in the APR were also relatively small: around 

80 percent of changes were less than 25 basis points in absolute value.

FIGURE 3: DISTRIBUTION OF CHANGE IN VARIOUS LOAN TERMS BETWEEN THE FIRST AND LAST LOAN 

ESTIMA TE AMONG LOANS THAT EXPERIENCED A CHANGE FOR THE RESPECTIV E TERM
24 CONSUMER FINANCIAL PROTECTION BUREAU

Focusing on changes between Closing Disclosures, Figure 4 plots the distribution of changes of 

numeric loan terms between first and last Closing Disclosure among loans with a change. The 

distributions of changes in loan amount, LTV ratio, and APR were narrower than the changes 

between the first and last Loan Estimate. However, the distribution of interest rate changes was 

only slightly less dispersed than the corresponding distribution in Figure 3. 

FIGURE 4: DISTRIBUTION OF CHANGE IN VARIOUS LOAN TERMS BETWEEN THE FIRST AND LAST 

CLOSING DISCLOSURE AMONG LOANS THAT EXPERIENCED A CHANGE FOR THE 

RESPECTIV E TERM

APR is a term that incorporates both the interest rate and non-interest mortgage costs such as 

any points, mortgage broker fees, and other charges. Changes to APR were more common than 
25 CONSUMER FINANCIAL PROTECTION BUREAU

changes in the interest rate, but the APR changes were generally smaller. This pattern likely 

reflects relatively frequent and small changes in non-interest mortgage costs.44 

The TRID Assessment Survey of Mortgage Originators (Lender Survey) asked respondents 

about strategies their institutions used to avoid tolerance violations (that is, to forgo violating 

limits on fee increases at or before closing).45 Table 8 shows the share of respondents who 

reported disclosing fees at the top of the fees’ range to avoid tolerance violations. Lenders were 

more likely to say they “almost always” used this strategy after the TRID Rule took effect. 

Respondents reported employing this strategy frequently in all time periodshowever, with 

about 60 percent of respondents saying their institution used this strategy either “Often” or 

“Almost Always.”46 The use of this strategy implies that mortgage costs would often need to be 

adjusted down from initial estimates. These changes would result in a change to APR, but not 

interest rate, and so could account for some of the difference between the share of mortgages 

with changes in interest rate and share with changes in APR. It could also explain why changes 

in APR appeared relatively small and were more likely to be reductions than increases.

TABLE 8: PERCENTAGE DISTRIBUTION OF LENDER SURVEY RESPONDENTS WHO REPORTED THEIR 

INSTITUTION DISCLOSED ESTIMA TED FEE AMOUNTS AT THE TOP OF A FEE’S RANGE TO 

AVOID TOLERANCE VIOLATIONS (AMONG RESPONDENTS WHO RESPONDED TO THE 

QUESTIONS)

Frequency

In the twelve months before

the TRID Rule’s effective date

In the twelve months after the 

TRID Rule’s effective date

In calendar 

year 2018

Almost Always 33.3 42.4 40.9

Often 22.6 19.6 20.4

 

44 A s described abov e, APR is a function of sev eral other mortgage terms. Changes to APR could also reflect changes 

to loa n amount or maturity term, for example. 

45 See Bu reau of Consumer Fin. Pr ot., Integrated Mor tgage Disclosures Under the Real Estate Settlement Procedures 

A ct (Regulation X) and the Truth in Lending A ct (Regulation Z) Rule A ssessment, A ppendix D, TRID A ssessment 

Su rvey of Loan Originators, qu estion 21 (Oct. 1, 2020), https://www.consumerfinance.gov /data-research/researchr eports/trid-rule-assessment. 

46 In lin e with these results, in r esponse to the Nov ember 2019 RFI, sev eral industry commenters stated that creditors

ov erestimate closing costs on disclosures because creditors fear violating the tolerance limits. See Bureau of 

Con sumer Fin. Prot., Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation 

X) and the Truth in Lending Act (Regulation Z) Rule Assessment Appendix B: Comment summary. (Oct. 1, 2020), 

h ttps://www.consumerfinance.gov /data-research/research-reports/trid-rule-assessment. 
26 CONSUMER FINANCIAL PROTECTION BUREAU

Frequency

In the twelve months before

the TRID Rule’s effective date

In the twelve months after the 

TRID Rule’s effective date

In calendar 

year 2018

Sometimes 19.4 13.0 15.1

Rarely 18.3 12.0 10.8

Never 6.5 13.0 12.9

Sample size 93 92 93

More generally, the Loan Officer Survey asked respondents to compare the accuracy of the GFE 

to the accuracy of the Loan Estimate, on average.47 About half of respondents thought the GFE 

and Loan Estimate were equally accurate, about one quarter thought the Loan Estimate was 

more accurate, and about one quarter thought the GFE was more accurate. In addition, the 

Loan Offer Survey asked about how often respondents thought the Closing Disclosure was an 

accurate representation of final loan terms and costs.48 About 31 percent responded, “Almost 

Always,” compared with about 47 percent who responded either “Often” or “Sometimes.” The 

remainder, nearly 16 percent, responded either “Rarely” or “Never.”

 

47 See Bu reau of Consumer Fin. Pr ot., Integrated Mor tgage Disclosures Under the Real Estate Settlement Procedures 

A ct (Regulation X) and the Truth in Lending A ct (Regulation Z) Rule A ssessment, A ppendix D, TRID A ssessment 

Su rvey of Loan Officers, qu estion 13. (Oct. 1, 2020), https://www.consumerfinance.gov /data-research/researchr eports/trid-rule-assessment. 

48 Id. a t question 14.
27 CONSUMER FINANCIAL PROTECTION BUREAU

6. Mortgage changes after 

consummation

According to the TRID Rule, creditorsmust provide a post-closing Closing Disclosure (postclosing CD), a correctedClosing Disclosure generated after a mortgage is consummated—if an 

event occurs during the 30-calendar-day period after consummation that: 1) is in connection 

with the settlement, 2) causes the Closing Disclosure to become inaccurate, and 3) results in a 

change to an amount paid by the mortgage consumer from what was previously disclosed.49 In 

these cases, a post-closing Closing Disclosure must be provided within 30 calendar days after 

receiving information sufficient to establish that such an event has occurred. 

Through discussions with industry, the Bureau understands that post-closing Closing 

Disclosures are also generatedfor other reasons, even when not required by the TRID Rule. The 

Bureau understands that common examples of changes that lead to a creditor generating apostclosingClosing Disclosure include: updating a loan file based on information obtained after the 

30-calendar-day period, sales of the mortgage by the originator, andenrollment in secondary 

market loan programs.50 The Bureau also understands that because these types of changes often

would not manifest in additional charges to consumers, post-closingClosing Disclosures 

generated for these reasonsmay not be sent to consumers and would be capturedonly as an 

additional document in a loan file. 

Figure 5 plots the distribution of elapsed time from closing to the last post-closingClosing 

Disclosure among files thatincluded a post-closingClosing Disclosure. Of these loans, around 

three-quarters generatedthe last post-closingClosing Disclosure within three weeks of closing. 

 

49 § 1 026.19(f)(2)(iii), Comment 19(f)(2)(iii)-1 . See also § 1 026.19(f)(4)(ii) (similarly requiring settlement agents to 

pr ov ide a post-closing Closing Disclosure if an ev ent occurs during the 30-calendar-day period after consummation 

th at results in a change to an amount paid by the seller).

50 Th ese may in turn be due to investors in the secondary market requiring a corrected loan file as a defense from civil 

lia bility under TILA 130(b).
28 CONSUMER FINANCIAL PROTECTION BUREAU

FIGURE 5: DISTRIBUTION OF CALENDA R DAYS BETWEEN CLOSING AND THE DATE THE LAST POSTCLOSING CD WAS GENERATED (LAST BIN CONTAINS ALL VALUES LONGER THAN 90 DAYS)
29 CONSUMER FINANCIAL PROTECTION BUREAU

Figure 6 plots the distribution of the number of post-Closing Disclosures issued across 

mortgages. Almost half of the mortgages had at least one post-closingClosing Disclosure. 

FIGURE 6: DISTRIBUTION OF NUMBER OF POST-CLOSING CDS GENERATED 

Table 9 describes how often certain loan terms change between the last Closing Disclosure 

providedat or before consummation and the last post-closingClosing Disclosure generated, 

among those that generateda post-closingClosing Disclosure. Both the finance charge and the 

APR differed for about one percent of these loans. This further underscores the fact that many 

post-closingClosing Disclosures do not contain changes to the loan terms for the consumer.

TABLE 9: FREQUENCY OF CHANGE IN VARIOUS LOAN TERMS BETWEEN THE LAST CD PROVIDED 

BEFORE CONSUMMATION AND THE LAST POST-CLOSING CD 

Item Frequency of change (percent)

Maturity term 0.002 

Loan amount 0.8

Loan-to-value ratio 0.8
30 CONSUMER FINANCIAL PROTECTION BUREAU

Item Frequency of change (percent)

Interest rate 0.02 

Annual percentage rate (APR) 1.1

Finance charge 1.0

Loan purpose 0.00

Loan type 0.00

Rate type 0.02 
31 CONSUMER FINANCIAL PROTECTION BUREAU

7. Conclusion

This Data Point examines data from disclosure forms for over 50,000 mortgages to explore how 

mortgages evolve throughoutthe origination process. Although these data are likely not 

representative of all mortgages in the United States and only cover mortgages originated after 

the Bureau’s TRID Rule took effect, the dataprovide a window into mortgage dynamics—a topic 

on which little was previously known.

Based on these data, both Loan Estimates and Closing Disclosures appear to have been 

delivered quickly. Althoughthe TRID Rule requires lenders to provide Loan Estimates within 

three business days, the median amount of time between application and provision of the Loan 

Estimate was only one calendar day, and the interquartile range was one to three days. 

Similarly, while the TRID Rule requires lenders to provide a Closing Disclosure at least three 

business days before the mortgage is consummated, the median amount of time between when 

the firstClosing Disclosure was provided and closing was six calendar days, and the 

interquartile range was four to eight days. 51

According to survey data, the TRID Rule appears to have resulted in consumers receiving their 

Closing Disclosures a number of days earlier than when pre-TRID consumers typically received 

HUD-1 settlement statements. Whereas consumers now must receive a Closing Disclosure at 

least three business days before consummation, more than 60 percent of loan officers who 

responded to the survey recalled providing the HUD-1 settlement statement to consumers only 

one day or less before closing.52 On the other hand, it is not clear that the TRID Rule resulted in 

potential borrowers receiving their first disclosure form sooner. After first contact with a 

borrower, survey respondents recalled providing the first GFE with about the same timing with 

which they provide the first Loan Estimate.

The Bureau’s Compliance Tool data only track certain mortgage fields, and therefore this Data 

Point cannot measure how disclosure forms change in all dimensions. Nevertheless, the data 

show that mortgage terms or costs change for most mortgages in the analysis sample and that 

changes can occur at all stages of the mortgage origination process. 53 In a technical sense, this

means that most initial Loan Estimates are at least partly inaccurate. However, the Bureau’s 

data do not include reasons for why the Loan Estimate changed—a change could have been 

 

51 Con summation and closing may occur on different days. See supra n ote, 29.

52 Id.

53 Usin g disclosure reissuance as an indicator of a change in terms or costs would indicate that almost 90 percent of 

m ortgages experience some change.
32 CONSUMER FINANCIAL PROTECTION BUREAU

initiated by a lender, their affiliates, or third-party service providers. Changes may also have 

been initiated at the request of the consumer, been due to changes initiated by the seller (in the 

case of a purchase transaction), or been due to circumstances out of the control of any of these 

parties (for example, an unexpected appraisal value). 

The frequency of changes varied widely among the mortgage terms tracked in the sample of data 

from Compliance Tool data analyzed in this Data Point. The APR changed for more than 40 

percent of mortgages, the loan amount and the loan-to-value ratio changed for almost a quarter

of mortgages, and the interest rate changed for about eight percent. In contrast, changes to 

maturity, loan type (conventional, VA, FHA, USDA), rate type (fixed or adjustable-rate), and 

loan purpose (purchase, refinance, etc.) were relatively rare.

Similarly, the magnitude of changes varied widely among the mortgage terms tracked in Bureau 

data. Changes to loan amount and APR were relatively muted, whereasmany changes to 

interest rate and LTV ratio were relatively large. The disparity between the magnitude of 

changes in APR and interest rate are at least partly mechanical—APR would likely show a small 

change in response to small changes in loan amount or closing costs. According to survey data, 

this disparity may also be due to precautions lenders took to avoid tolerance violations. More 

than three quarters of respondents saidtheir institution “sometimes,” “often,” or “almost 

always” estimated fees at the top of their range to avoid possible tolerance violations. The use of 

this strategy would imply that mortgage costs on the Closing Disclosure would often be lower 

than initial estimates, and these changeswould subsequently show up in the Bureau’s data as a 

small decrease in APR. (The Bureau’s Compliance Tooldata do not include mortgage costs.)

Finally, this Data Point reports on post-closingClosing Disclosures. These are Closing 

Disclosures generated after a mortgage is consummated. Almost half of mortgages in the 

sample of the Bureau’s Compliance Tool datahad a post-closing Closing Disclosure. In the 

mortgage terms tracked in Bureau data, the finance charge and APR changedbetween the last 

Closing Disclosure and the last post-closingClosing Disclosure for only about one percent of 

mortgages with a post-closingClosing Disclosure, and changes to other loan terms were even 

rarer. This underscores the fact that many post-closingClosing Disclosures are generated in 

response to secondary market requirements and do not necessarily reflect substantial changes to 

the mortgage.