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Changed Circumstances

QUICK SUMMARY

A changed circumstance is a real event that lets the lender revise fees that would otherwise be stuck inside the tolerance rules. The appraisal comes in and the loan amount changes. The borrower locks a rate. A storm changes the insurance. The borrower switches programs. "We decided to charge more" is not a changed circumstance. The revision has to be tied to the event, and it has a timing rule.

A lender can revise the fees on your Loan Estimate only for specific reasons listed in federal rules, and only for the charges actually affected. The main reasons are a changed circumstance that affects settlement charges or your eligibility, a change you asked for, locking or relocking the rate, and a few others. The lender generally has to send the revised Loan Estimate within three business days of learning about the change (12 CFR 1026.19(e)(3)(iv) and (e)(4)). A revision is not a free reset of every fee.

Why this rule exists

The Loan Estimate is a good faith estimate. Regulation Z sets tolerances: some fees cannot increase at all, some can increase together by up to 10 percent, and some can change freely. See which fees can change. A valid revision lets the lender compare final costs to the revised figure instead of the original, but only for the fees the event changed.

The permitted reasons

  • A changed circumstance affecting settlement charges. An extraordinary event, information specific to you or the transaction that the lender relied on and that turns out to be inaccurate or changes, or new information the lender did not rely on.
  • A changed circumstance affecting eligibility. For example, income that cannot be verified as stated.
  • Revisions you request. Changing the loan program, the loan amount, or the down payment.
  • Interest rate dependent charges. When the rate is locked after the first Loan Estimate, points and lender credits are revised to match the lock. See rate locks.
  • Expiration. If you do not say you intend to proceed within 10 business days after the Loan Estimate is provided, the lender can issue a new one.
  • Delayed settlement on new construction. When the lender reasonably expects settlement more than 60 days after the first Loan Estimate and disclosed that it may revise.

What a revision does not do

The revision resets the affected charges only. A rate lock revises the rate and the points or credits. It does not, by itself, justify a higher appraisal fee. A lower appraised value can change the loan amount, the mortgage insurance and the cash to close, but it does not explain a higher origination charge with no new service. If the lender misses the timing, it may not be allowed to use the higher number. A mistake on the original estimate is not a changed circumstance.

After the Closing Disclosure

Once the Closing Disclosure is out, revisions are made on a corrected Closing Disclosure. Three changes restart the three business day wait before closing: the APR becomes inaccurate beyond the allowed tolerance, the loan product changes, or a prepayment penalty is added. Other changes need a corrected disclosure at or before closing but no new wait.

Fictional example

Fictional example: a buyer in Arlington applies with a planned loan amount. The appraisal comes in below the contract price, so the buyer renegotiates and the loan amount drops. The lender sends a revised Loan Estimate two business days later showing the new amount, the new mortgage insurance and the new cash to close. That is a valid changed circumstance. If the same revised estimate also raised the underwriting fee with no new service, the buyer should ask which event changed that line.

Questions to ask when you get a revision

  • What happened, and on what date did the lender learn about it?
  • Which lines changed, and how is each one tied to that event?
  • Did the revision go out within three business days?
  • Does the change affect the closing date or the cash to close?

Keep every version of your Loan Estimate. Comparing them line by line is the fastest way to see what moved.

Next step

If you received a revised Loan Estimate and want a second set of eyes on what changed and why, send it over. Book a call, or start an application.

Related questions

Sources

Links checked Oct 21, 2026.

About the author: McKade Lively, NMLS 2704474, American Pacific Mortgage Corporation dba True North Home Loans, NMLS 1850.

Equal Housing Opportunity.

Last reviewed: Oct 2026

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McKade Lively, NMLS #2704474. Equal Housing Opportunity.