I'm Bond Peter Njoku, a mortgage loan officer in Garland, and there is a specific moment where DFW buyers lose money quietly: the three days between when the Closing Disclosure arrives and when they sign it.
Almost everything written about the Closing Disclosure is a tour of the form — here's page one, here's page two, here's what Section G contains. That's useful the first time you see the document. It is not what you need at 9pm the night before closing, when the real question is narrower and more urgent: what am I looking for, and what do I do if I find it?
So this is a challenge list, not a tour. Five errors, ranked by how often I catch them and what they cost, plus the mechanism that forces your lender to fix them.
What is the Closing Disclosure, and how long do I have to review it?
The Closing Disclosure (CD) is the five-page federal form that states your final loan terms and every dollar changing hands at closing. Under the TRID rule it must be in your hands at least three business days before consummation — a deliberate cooling-off window so you can compare it against the Loan Estimate (LE) you received when you applied.
That three-day window is your leverage, and most buyers waste it. Do two things the moment the CD lands: pull up your original Loan Estimate, and set aside forty minutes. Everything below is a comparison between those two documents.
Which Closing Disclosure fees are allowed to increase in Texas?
Before you can judge whether a number is wrong, you need to know which bucket it sits in. TRID sorts every charge into three tolerance categories, and the category — not the dollar amount — determines whether you have a claim.
| Section | What's in it | Tolerance | What to do if it increased |
|---|---|---|---|
| A — Origination charges | Origination fee, underwriting, processing, discount points | Zero | Demand a corrected CD and a refund. No increase is permitted without a documented changed circumstance. |
| B — Services you couldn't shop for | Appraisal, credit report, flood determination, tax service | Zero | Same — the lender chose these providers, so the lender owns the estimate. |
| C — Services you could shop for | Title, survey, pest inspection (when you used a provider from the lender's written list) | 10% aggregate | Add the group up. If the total rose more than 10%, the overage must be cured. Individual line swings inside the group are fine. |
| D — Total loan costs | A + B + C | Derived | Check the arithmetic. I have caught addition errors here. |
| E — Taxes and government fees | Recording fees, transfer taxes (Texas has no real estate transfer tax) | Unlimited | Verify the recording fee is plausible; there's no tolerance claim. |
| F — Prepaids | Prepaid interest, first-year homeowners insurance, prepaid MI | Unlimited | Check the daily interest math and the number of days. |
| G — Initial escrow deposit | Tax and insurance reserves | Unlimited | Check the tax rate used — see error 4 below. |
| H — Other | Owner's title policy, HOA transfer, home warranty | Unlimited | Check who the contract said pays each one. |
Here is the part the competing articles leave out. When a zero-tolerance fee increases without a valid changed circumstance, the lender is required to cure it: issue a corrected Closing Disclosure and refund the excess to you. The cure may be made up to 60 days after consummation. So even if you've already closed and then spot it, you still have a remedy. Buyers who think the CD is take-it-or-leave-it leave money behind.
Error 1: A lender fee went up from the Loan Estimate
This is the most common and the most clearly actionable. Open both documents to Section A and compare every line: origination fee, underwriting fee, processing fee, administration fee, discount points.
Any increase in Section A or Section B is a zero-tolerance violation unless the lender can document a valid changed circumstance — and that term is narrower than lenders sometimes imply. It means something genuinely changed about your transaction: you switched loan programs, your loan amount changed, the appraisal revealed the property is in a flood zone, your credit was re-pulled and the score moved you to a different pricing tier. "Our rate sheet changed" is not a changed circumstance. "We underestimated" is not a changed circumstance.
Ask the question in writing: "Which changed circumstance supports this increase, and when was the revised Loan Estimate issued?" A lender who raised a fee because of a legitimate changed circumstance was required to send you a revised LE within three business days of learning about it. If no revised LE exists, the increase is almost certainly a violation.
Error 2: The loan terms on page 1 don't match what you agreed to
Page one carries five things worth checking character by character, because they are the terms you'll live with for thirty years:
- Loan amount — and whether it matches after any price renegotiation or seller credit
- Interest rate — compare against your signed rate lock, not your memory
- Loan term — 30 years versus 25 years is an easy data-entry slip and a costly one
- Prepayment penalty and balloon payment — both should read "NO" on a standard DFW purchase loan
- Whether the rate can increase — if you locked a fixed rate, this must say no. On an ARM, verify the index, the margin, the first adjustment date and the caps
If your loan product changed — fixed to adjustable, 30-year to 15-year — that is one of the three events that genuinely restarts the three-business-day clock. So does an APR that's now inaccurate by more than 0.125% on a standard fixed-rate loan, and adding a prepayment penalty. Nothing else resets it.
I want to be blunt about this, because I've seen it used to pressure buyers: a misspelled name, a corrected proration, a fixed escrow number or a fee change within tolerance does not delay your closing by three days. If someone tells you that correcting an error will blow up your closing date, they are either mistaken or they'd rather you didn't push. Several of the pages currently ranking on Google for this topic get this wrong, which is how the myth spreads.
Error 3: Texas-specific fee overcharges in the title section
Texas title insurance is different from most states: premiums are promulgated by the Texas Department of Insurance, meaning the rate is set by regulation, not by the title company. That makes overcharges checkable in a way they aren't elsewhere. Three to hunt for:
Title premium above the promulgated rate. The owner's policy (T-1) and the lender's policy (T-2) are priced off a published schedule based on the policy amount. When the lender's policy is issued simultaneously with the owner's policy, the T-2 is issued at a nominal charge — commonly around $100 — rather than a second full premium. If you see a full-price lender's policy sitting next to a full-price owner's policy, ask whether simultaneous issue was applied. That one question has been worth well over a thousand dollars to clients of mine.
Survey billed twice, or billed both ways. In Texas you take one of two paths: use the seller's existing survey with a T-47 residential real property affidavit (inexpensive), or order a new survey (roughly $450–$650). I regularly see CDs where a new survey was ordered and a T-47 was prepared and billed, or where the survey charge appears in both Section C and Section H. Pick a lane; you shouldn't pay for both.
A T-36 endorsement on a house that isn't a condo. The T-36 is a condominium endorsement. If you are buying a single-family home in Garland or Mesquite, there is no reason for one on your CD. It is a small charge and a clean catch — and notably, none of the pages currently ranking for "Texas closing disclosure" mention it. While you're in that section, confirm the T-19.1 restrictions endorsement and any survey deletion endorsement were actually ordered for your file.
My Texas title insurance cost guide has the full rate structure if you want to verify a premium yourself.
Error 4: Your escrow account was funded off the wrong tax rate
Section G is where DFW buyers get hurt the most, and almost nobody checks it, because an escrow error doesn't cost you money at the table — it costs you twelve months later.
Here's the arithmetic to run. Take your purchase price, multiply by your county's effective rate, divide by twelve. On a $350,000 home in Dallas County at roughly 2.0%, that's $7,000 a year, or $583 a month. Now check what Section G and your projected payments on page one actually used. The three ways it goes wrong:
- The prior year's rate was used on a property whose assessment just jumped — common in the fast-appreciating parts of DFW
- The seller's exempted bill was used. If the seller had a homestead exemption and you haven't filed yours yet, their bill understates your taxes significantly. You're underwritten on the unexempted figure; make sure your escrow was funded on it too
- A MUD or PID rate was omitted on new construction in Forney, Prosper or Royse City, which can understate the rate by half a point or more
An under-funded escrow account produces an escrow shortage at the first annual analysis, and your payment jumps — often by $150 to $300 a month — to repay the shortfall and rebuild the cushion. Nobody warned you because technically nobody made a "mistake" you could challenge. While you're there, confirm the cushion is no more than two months of payments, which is the RESPA maximum. My posts on Texas property taxes and your payment and property tax proration at closing cover both sides of this.
Error 5: Your seller credit is missing or wrong
This one is urgent in October 2026 specifically. Roughly 49% of DFW closings now include a seller concession, with a median above $17,000 — which means about half the Closing Disclosures crossing my desk have a credit on them that has to be verified against the contract.
Check three things. Is the credit there at all, in the seller-paid column or on page three in the Summaries of Transactions? Is the amount right — matching the executed contract and any amendments, not the original offer? And is it applied the way you negotiated — toward closing costs, toward discount points, or toward a temporary buydown? A concession you intended to spend buying your rate down is worth far more than the same dollars dropped against closing costs, and I've seen the allocation quietly change between the LE and the CD.
One related trap: a credit that exceeds your program's concession cap or exceeds your actual eligible costs gets trimmed, and the unused portion is not refunded to you in cash. If your CD shows less credit than your contract promised, that may be the reason — and the fix is to redirect the excess into a rate buydown before closing, not to argue about it afterward. I walk through that conversion in my post on converting a seller concession into a rate buydown.
A real DFW example: $2,100 caught on a Garland closing
Last year a buyer came to me after a closing had already been scheduled with another lender — she wasn't my client, she just wanted a second opinion on the paperwork. She was buying a $312,000 home in Garland with 5% down. Her Closing Disclosure and her original Loan Estimate were seventy-one days apart, and nothing about her transaction had changed in between.
Here's what the comparison turned up:
| Item | Loan Estimate | Closing Disclosure | Difference | Why it was challengeable |
|---|---|---|---|---|
| Origination fee (A) | $1,295 | $1,795 | +$500 | Zero tolerance, no revised LE on file |
| Underwriting fee (A) | $695 | $995 | +$300 | Zero tolerance |
| Appraisal fee (B) | $650 | $900 | +$250 | Zero tolerance; no re-inspection was ordered |
| Credit report (B) | $75 | $150 | +$75 | Zero tolerance |
| Survey (C) | $575 | $1,150 | +$575 | Billed twice — a new survey plus a T-47 path |
| T-36 endorsement (H) | — | $125 | +$125 | Condominium endorsement on a single-family home |
| Lender credit (J) | −$275 | $0 | +$275 | Promised credit dropped off entirely |
| Total | $2,100 |
She sent one email listing each line, the tolerance category, and a request for the changed-circumstance documentation and revised Loan Estimate supporting each increase. The lender came back within a day, issued a corrected Closing Disclosure, removed the duplicate survey and the T-36, restored the $275 credit, and cured the Section A and B increases as a lender credit at closing. She closed on schedule — because none of those corrections reset the three-day clock — and she brought $2,100 less to the table.
That email took her twenty minutes to write. It is the best-paid twenty minutes in the entire homebuying process.
What's my pre-signing checklist?
- Get the CD at least three business days out. If it's late, say so immediately.
- Put the original Loan Estimate beside it. Every check below is a comparison.
- Compare Sections A and B line by line. Any increase needs a documented changed circumstance and a revised LE.
- Total Section C both ways and confirm the group didn't rise more than 10%.
- Verify page 1: loan amount, rate against your lock, term, prepayment penalty, balloon, and that a fixed rate cannot increase.
- Recompute the escrow: price × county rate ÷ 12. Confirm the cushion is two months or less.
- Check the title section for simultaneous issue, a double-billed survey and any endorsement that doesn't fit your property type.
- Confirm your seller credit matches the executed contract in amount and in how it's applied.
- Verify wiring instructions by phone, using a number you looked up independently. Never from an email. Wire fraud is the one error on this list you cannot cure afterward.
- Confirm your exact cash to close with the title company 48 hours ahead.
If you want help with any of this, send me your Closing Disclosure and your Loan Estimate — I'll compare them whether or not I originated the loan. My full walkthrough of the form is in the Texas Closing Disclosure explained, the cost breakdown is in understanding Texas closing costs, and if you're still early in the process, how long closing takes in Texas will tell you when to expect the document. Buyers in my home market can also start at my Garland mortgage page.
Frequently Asked Questions
What should I check first on my Texas Closing Disclosure?
I'm Bond Peter Njoku (NMLS #2670329), and the first thing I do is put the Closing Disclosure next to the original Loan Estimate and compare Section A and Section B line by line. Those are the zero-tolerance sections — the lender's own origination, underwriting and processing fees, plus the services you weren't allowed to shop for. Not one of those numbers may increase from the Loan Estimate without a valid changed circumstance, so any increase there is a violation and the lender owes you a refund. After that I check the interest rate, the loan term, the loan amount and the cash to close. Call or text me at 469-545-7180 and I'll do that comparison with you before you sign.
What happens if a fee on my Closing Disclosure is higher than my Loan Estimate?
I'm Bond Peter Njoku (NMLS #2670329), and it depends which tolerance bucket the fee sits in — but if it's a zero-tolerance fee, the lender must cure it. That means issuing a corrected Closing Disclosure and refunding you the excess, and under TRID the cure can be made up to 60 days after closing, so you are not out of options even if you've already signed. Section C fees carry a 10% aggregate tolerance, meaning that group can rise collectively by up to 10%. Sections E through H can change without limit. You don't have to accept an unexplained increase at the table — ask what changed circumstance justifies it, in writing. Call or text me at 469-545-7180 if you need help pushing back.
Does a mistake on my Closing Disclosure delay my closing by three days?
I'm Bond Peter Njoku (NMLS #2670329), and usually not — this is the most common myth I correct. Only three changes restart the three-business-day waiting period: the APR becomes inaccurate (more than 0.125% off on a standard fixed-rate loan), the loan product itself changes, or a prepayment penalty is added. A misspelled name, a corrected tax proration, a fixed escrow figure or a fee change inside tolerance does not reset the clock. So fixing an error before you sign generally costs you nothing — which means there is no reason to let something slide to protect your closing date. Call or text me at 469-545-7180 and I'll tell you whether your specific correction resets anything.
Can I be charged for a new survey and a T-47 affidavit on the same Texas closing?
I'm Bond Peter Njoku (NMLS #2670329), and you generally shouldn't be paying for both paths at once. In Texas you either use the seller's existing survey — supported by a T-47 residual affidavit, which is cheap — or you order a new survey for roughly $450 to $650. I regularly see Closing Disclosures where a new survey was ordered and a T-47 was also prepared and billed, or where the survey appears in two different sections. The same goes for a T-36 endorsement, which is a condominium endorsement: if you're buying a single-family home, you should not see one. Both are easy wins when you catch them. Call or text me at 469-545-7180 and I'll review your title charges against the TDI promulgated rates.
Want a second set of eyes on your Closing Disclosure?
I'm Bond Peter Njoku (NMLS #2670329). Send me your CD and your original Loan Estimate and I'll compare them line by line before you sit down at the title company — whether or not I'm your lender. Call or text me at 469-545-7180, message me on WhatsApp, or start your pre-approval online.