The Loan Estimate is bound by tolerance rules. Some charges cannot increase at closing, some can increase only within a combined 10 percent limit, and some can change with the facts. Those limits would be unfair if the loan itself never changed, but loans do change. The appraisal comes in at a different value. The borrower locks a rate. The borrower decides on a different program. The rules account for that through changed circumstances.
A changed circumstance lets the lender issue a revised Loan Estimate that resets the baseline for the affected charges. The tolerance test at closing then compares against the revised figures instead of the original ones. The event has to be real, the revision has to be tied to it, and the timing has to follow the rule.
The rules are in Regulation Z, 12 CFR 1026.19(e)(3)(iv) and the surrounding TRID provisions. Source: 12 CFR 1026.19.
Regulation Z lists specific grounds for a revised Loan Estimate. The main ones:
Each reason allows a revision only to the extent the event actually affects the charges.
In a Fort Worth purchase, the most common changed circumstances are:
A revision resets the charges affected by the event, and only those. A rate lock revises the rate, points, and lender credits. It does not, by itself, justify a higher appraisal fee or a new processing charge. A change in loan amount after the appraisal can affect charges calculated as a percentage of the loan, mortgage insurance, and title insurance premiums tied to the loan amount. It does not justify an unrelated increase in the origination fee when no new service is involved.
A useful test for any revised estimate: identify the event, then check which lines it should change. Lines that moved without a connection to the event deserve a question.
The lender generally must provide the revised Loan Estimate within three business days after receiving information sufficient to establish that the changed circumstance occurred. If the revision arrives late, the lender may not be allowed to use the higher figures for the tolerance test. That is a lender compliance matter, and the borrower should not be asked to waive it.
There is also a limit at the end of the process. A revised Loan Estimate cannot be provided on or after the date the Closing Disclosure is provided, and the borrower must receive a revised Loan Estimate no later than four business days before consummation. After the Closing Disclosure is out, changes are reflected on a corrected Closing Disclosure instead.
Once the Closing Disclosure has been provided, the lender can still use a valid changed circumstance to reset charges, by reflecting it on a corrected Closing Disclosure within the rule's timing.
Separately, three kinds of change require a corrected Closing Disclosure and a new three-business-day waiting period before consummation:
Other corrections, such as most fee changes, can be made on a corrected disclosure without a new wait. Most revisions, before or after the Closing Disclosure, do not move the closing date.
Fictional example: the appraisal supports a lower value than the original estimate assumed. The loan amount drops, and mortgage insurance coverage changes with the new loan-to-value. The lender sends a revised Loan Estimate showing the new amount, the new mortgage insurance, and the new cash to close. That is a valid changed circumstance, and the affected lines reset.
If the same revised estimate also shows a higher origination charge, with no new service and no connection to the loan amount, the appraisal does not explain it. The borrower should ask which line the event actually changed. A lender who cannot tie the increase to the event cannot rely on it for the tolerance test.
A changed circumstance has to be provable after the fact. Lenders keep a record of what the event was, when they learned of it, which charges it affected, and when the revised estimate went out. Regulators and investors review those records, and a revision without a documented reason can be treated as if it never happened for tolerance purposes.
That record-keeping is why a loan officer may ask a borrower to confirm a requested change in writing, such as a new down payment or a switch from one program to another. The written request establishes the date and the reason.
A rate lock carries an expiration date. If closing is delayed past that date, the lock may need to be extended or the loan relocked, and either can change pricing. How that cost is handled depends on why the delay happened and on the lender's lock policy, which should be explained when the lock is taken. Any revised estimate that follows still has to rest on a valid reason under the rule. Asking at the time of the lock how extensions work avoids a surprise later.
A changed circumstance is an event that happened, or information that was new or turned out to be different. A mistake on the original estimate is something else. If the lender simply underestimated its own fee, that error is the lender's responsibility. It does not allow a reset.
A changed circumstance is narrower than "anything changed." It must be one of the listed reasons, and it resets only what it affects.
Most revisions do not restart a closing clock. Only the three Closing Disclosure triggers create a new waiting period.
For which fee groups a revision affects, see fee tolerances. For the final form and its own wait, see the Closing Disclosure.
If you received a revised Loan Estimate and are not sure what drove it, send me both versions and I will tie each changed line to the event, or tell you which ones need a question. Book a call, or start an application.
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