TRID Tolerances & Cures
One of the key components of the TRID Rule is the concept of tolerances. Essentially, you will be held to specific tolerance levels for certain fees that you disclose on the Loan Estimate. There are certain fees that are subject to a 0% tolerance and others that fall under a 10% tolerance. There are even some fees where the tolerance is unlimited, but you must still disclose them in good faith. If you don’t have a valid changed circumstance to reset those tolerances, you are, in a sense, bound to what you initially disclosed. For example, if you disclose that a credit report will cost $40 on the Loan Estimate, but it actually ends up costing $50, the borrower still only has to pay the $40, since this is a 0% tolerance item. The institution would be responsible for the additional $10. There are at least a couple of different ways this can be disclosed, depending on the scenario and the particular fees in question.
Jerod explains one option in the video:
2025/03/26
Jerod Moyer
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!