TRID and cure management

Every fee, every clock, every cure — re-derived from the file

A tolerance cure is the last line of a chain of decisions about each fee. Get any link wrong and the cure is wrong with total confidence.

Which bucket a fee sits in depends on who was paid, whether the borrower could shop, which provider list governed, and how a government charge is assessed. Whether its baseline moved depends on a permitted reason, causation, a clock that starts when the creditor had enough information, and the disclosure that carried it. Sei’s agents decide each link separately, from the evidence in the file, record why, and refuse to guess where your policy has not answered. The same decision engine drives the disclosure desk and independent QC — so the desk and the auditor read the same rules, and the auditor never reads the desk’s answer.

Watching the clocks

Every disclosure clock on every file, fee tolerance across the zero, ten percent and unlimited buckets, and the cure cut before the document goes out rather than after an audit finds it.

Three properties the whole design is built on

It re-derives. It never reads a conclusion.
A tolerance figure your LOS calculated, a reset someone approved, a cure already recorded — the agents work each one out again from the evidence. An error in the file is found rather than inherited, and QC cannot confirm the file by reading it.
It abstains instead of guessing.
Where a rule needs your interpretation and you have not approved one, the result is manual review with the reason named. A plausible default looks identical in an audit record to a decision someone made, so the agent does not make one.
Every answer replays.
Each run records the evidence, the rules, your policies and the calendars it used. The same run replayed a year later gives the same answer, and every result points to the evidence trail behind it.

Send us a loan with a tolerance question on it. We will show you the cure the agent calculates, fee by fee, and where it differs from your file.

The mechanics, rule by rule

Each rule column cites the provision it is drawn from. Where a rule needs your interpretation, the agent applies the treatment you approved — or holds the fee for review.

01
Scope and rule selection
Reg Z § 1026.19(e)–(f)
Whether a loan is under the integrated disclosure rules at all, and which tests apply to it.
The rule
The Loan Estimate and Closing Disclosure rules apply to most closed-end consumer credit secured by real property or a cooperative unit.
HELOCs, reverse mortgages and chattel-secured manufactured housing are outside them and carry different disclosure regimes.
Where files break it
One checklist run on every loan, so a HELOC gets a zero-tolerance “pass” that reads like a computed answer
Scope decided from a loan-type label rather than product, purpose, lien, collateral and creditor facts
What Sei’s agent does
Decides scope from the loan’s facts before anything is calculated, and records which rules applied
Runs only the tests that apply. A test that does not apply produces no result at all — not a zero, not a pass — so “out of scope” is never confused with “in scope and unresolved”
02
Fee identity across versions
Reg Z § 1026.19(e)(3)
Which line on the final Closing Disclosure is the same charge as which line on the estimate that set its baseline.
The rule
Good faith is tested against the estimate that governed each charge, so every amount paid has to trace to the estimate it is measured against.
Where files break it
A fee relabelled between LE and CD reported as one fee removed and another added
A fee split in two, two merged into one, or moved between sections
A match on label alone, which produces a confidently wrong baseline — the worst failure, because it looks authoritative
What Sei’s agent does
Follows every fee from the first Loan Estimate through every revised LE, initial CD and corrected CD
Recognises relabels, section moves, splits and merges under your approved fee taxonomy and aliases
Leaves an uncertain match unresolved and names it, rather than forcing one
03
Placement and tolerance bucket
Reg Z § 1026.19(e)(3)(i)–(iii)
Which good-faith test a fee is held to on this loan — a property of the loan’s facts, not of the fee’s name.
The rule
Zero tolerance: charges paid to the creditor, the mortgage broker or an affiliate of either, other than for services the creditor does not require; services the consumer was not permitted to shop for; transfer taxes.
10% aggregate: recording fees, and third-party services the consumer could shop for and obtained from a provider on the written list, unless paid to an affiliate.
No specific limit: prepaid interest, property insurance premiums, initial escrow deposits, services shopped for off the list, and services the creditor does not require.
Where files break it
“We treat title as 10%” — true only when the borrower used a listed provider that is not an affiliate
Transfer taxes and recording fees carried under labels that do not separate them, so a zero-tolerance tax lands in the 10% pool
An affiliate’s fee treated as shoppable because shopping was permitted
Seller- or lender-paid portions tested as if the consumer paid them
What Sei’s agent does
Classifies each fee from the facts that decide it — who was paid, whether the service was required, whether the borrower could shop, which list governed, which provider was used and whether it is an affiliate — and keeps the evidence for each
Decides a government charge by how it is assessed — per instrument recorded, or on the loan amount, price or other transaction value — not by what the county calls it
Records which rule placed the fee, not just the bucket, so a reviewer can see why
Tests the consumer-paid portion only
04
Written provider list and shopping
Reg Z § 1026.19(e)(1)(vi)
Whether the shopping permission holds, which list governed, and whether the provider the borrower used was on it.
The rule
Where the consumer may shop, the creditor gives a written list identifying at least one available provider for each such service, in a document separate from the Loan Estimate, within the Loan Estimate’s three-business-day window.
A provider on a compliant list puts the fee in the 10% pool. A provider the consumer found elsewhere puts it under no specific limit.
Where files break it
Four distinct failures — no list, a list delivered late, a list with no usable provider for a required service, a list naming one unusable provider among usable ones — given one treatment, or none
A provider selection asserted with no evidence the borrower chose that provider
Provider records that do not match cleanly across the LOS, the invoice and the list
What Sei’s agent does
Reads every list version your systems issued, with its delivery evidence, and works out which one governed
Tests timing, content and provider availability, then resolves listed versus off-list against your provider and affiliate records and the selection evidence
Applies your approved treatment for each of the four failure states. Where you have not stated one, the fee goes to review instead of to a conservative-sounding default
05
Baselines and changed circumstances
Reg Z § 1026.19(e)(3)(iv), (e)(4)
Whether a fee’s baseline may move, by how much, and on which disclosure.
The rule
A revised estimate resets a baseline only for a permitted reason: a changed circumstance affecting settlement charges or eligibility, a revision the consumer requested, interest-rate-dependent charges at rate lock, expiration when intent to proceed comes more than ten business days after the LE (or any longer period the creditor allows), or, on a construction loan expected to settle more than 60 days after the LE, delayed settlement the creditor disclosed it might revise for.
The revised estimate is due within three business days of the creditor receiving information sufficient to establish the reason.
Only the increase the event actually causes resets.
A revised LE must be received no later than four business days before consummation and may not follow a Closing Disclosure. Inside that window, the reset rides on a CD.
Where files break it
Sufficient-information time is not a field anyone maintains, so the date the change was keyed in the LOS stands in for it — and no redisclosure can ever be late
An event that explains a $200 increase used to reset $500
A reset accepted because a changed-circumstance form exists, with no causal link to the fees it moved
What Sei’s agent does
Tests each reset fee by fee on four counts — permitted reason, causation, timing and the disclosure that carried it — and keeps the evidence for each
Separates the part of an increase the event supports from the part it does not, and treats the remainder under your approved rule
Reports an unverifiable reset separately from an invalid one: a gap in the evidence and a failed test are different findings
Treats a reduced lender credit as a charge increase that needs its own reset
06
Zero tolerance and the 10% pool
Reg Z § 1026.19(e)(3)(i)–(ii)
How much the consumer paid above what the valid baselines allow.
The rule
Zero tolerance: every dollar a consumer pays above the fee’s valid baseline is excess.
10% aggregate: the sum of the pool’s charges paid is compared with the sum of their estimates. Only the amount above 110% is owed, and only in aggregate — one member can rise sharply with no excess.
Where files break it
The pool baseline read off a disclosure’s printed total, or raised by a reset that was never valid
Increases tested per change rather than cumulatively: 6% and then 5% is 11%
A service that was never performed left in the pool, inflating the allowance
The pool’s excess assigned to whichever fee moved last
What Sei’s agent does
Computes zero-tolerance excess fee by fee, against each fee’s valid baseline
Tests the 10% pool cumulatively across the life of the loan, from the original estimates and accepted resets only, and keeps the excess at the level of the pool
Works to the cent. A malformed amount stops the calculation and is named, rather than being rounded into an answer
07
No specific limit is still a test
Reg Z § 1026.19(e)(3)(iii)
Whether an estimate with no percentage cap was nonetheless made in good faith.
The rule
The estimate must be consistent with the best information reasonably available to the creditor when it was disclosed, and the charge must be bona fide.
Where files break it
The bucket described internally as “unlimited” or “not tested”, and left out of review entirely
What Sei’s agent does
Reviews every such fee against the final amount and whether the service was performed
Applies your approved good-faith evidence standard. Without one, the fee is a named manual review — never a silent pass
08
Lender credits
Reg Z § 1026.19(e)(3)(i); comment 19(e)(3)(i)-5
Whether the credits the consumer was promised were provided, credit by credit and in total.
The rule
A decrease in a promised lender credit is an increase in a charge, and needs a valid reset. An increase, once disclosed, becomes the new baseline.
A credit promised toward a specific charge does not shrink when that charge comes in lower.
The shortfall is measured in aggregate: total promised against total provided, counting the general credit and creditor-paid specific costs together.
Where files break it
A cheaper appraisal netted against a reduced appraisal credit: the report shows no shortfall and the consumer is under-refunded
Specific and general credits indistinguishable in the file
Equal and opposite errors on two credits hidden by a total that matches
What Sei’s agent does
Tracks each promised credit on its own, and tests every reduction as a reset
Measures the shortfall in aggregate, across general credits and creditor-paid costs
Holds a credit whose purpose the file does not record for review, rather than inferring one
09
Cure: calculation, relief and closure
Reg Z § 1026.19(e)(3), (f)(2)(iv)
What is owed, what has actually reached the consumer, and what is still open.
The rule
Before consummation, an excess can be removed by reducing the charge or increasing a credit on a Closing Disclosure.
After consummation, the excess is refunded and a corrected CD reflecting the refund is delivered or mailed, each no later than 60 days after consummation.
Where files break it
A cure closed because a corrected CD shows a credit, with no proof the money reached the consumer
One payment counted against two findings
Detection date taken for the governing stage. A defect found before closing and still uncured at consummation is a post-consummation refund
What Sei’s agent does
Calculates the cure across fee excess, pool excess and credit shortfall without counting any dollar twice
Subtracts only relief proven to have reached the consumer. A refund that was proposed or issued but not delivered does not count, and a missing relief history never means zero
Names the actions the cure requires and keeps it open until each one is evidenced, on time
10
Clocks, waiting periods and business days
Reg Z § 1026.2(a)(6); § 1026.19(e)(1)(iii), (e)(4), (f)(1)(ii), (f)(2)
When each disclosure and refund was due, and whether consummation waited long enough.
The rule
Two business-day definitions. The general one — days the creditor’s offices are open for substantially all business functions — governs the initial LE and a revised LE. The specific one — every day but Sundays and federal public holidays — governs the seven-day wait after the LE, revised-LE receipt, Closing Disclosure receipt and the mailbox presumption.
The consumer must receive the Closing Disclosure at least three business days before consummation. An APR that becomes inaccurate, a changed loan product or an added prepayment penalty restarts that wait; other changes go on a corrected CD at or before consummation.
A disclosure delivered other than in person — by mail or electronically — is presumed received three business days after it is sent.
Where files break it
One calendar used for everything, so deadlines drift by a day and Compliance rejects the finding — and then the next one
A late refund (a due-by deadline) and an early closing (a not-before waiting period) reported as the same kind of finding
Time zone and after-hours cutoff left unstated
What Sei’s agent does
Counts each deadline on the calendar the rule requires, in your time zone and with your cutoff, and shows the dates it counted
Reports due-by deadlines and not-before waiting periods separately, and carries both the date a problem was found and the stage that governs its remedy
Tracks every deadline through to completion against the delivery and payment evidence your systems record

One decision engine, from fee to closed cure

The disclosure desk, QC and the LE and CD field values all come from one engine. Every decision carries its status, its evidence and the rule it applied.

Identity and placement
Which charge each line is across every disclosure, who imposes it, whether the borrower could shop, which provider list governed, which provider was used, and the bucket that follows.
Baselines and amounts
The valid baseline for every fee and credit, each reset accepted or rejected with its reason, what the consumer actually paid, and whether each service was performed.
Good-faith tests
Zero-tolerance excess fee by fee, the 10% pool in aggregate, the good-faith review where no percentage applies, and the lender-credit shortfall.
Cure
What is owed net of overlap, what relief has been proven delivered, what remains, and which corrected disclosure, if any, is required.
Timing and closure
Every due-by and not-before boundary on its own calendar, whether each was met, and whether the cure is complete, with your severity and hold policies applied.

The Loan Graph holds the facts. Documents are read by Document Intelligence, every value carrying the page or field it came from.

Seven outcomes, and why abstaining is one of them

A run whose summary is manual review is a successful run: it computed what it could and named what it could not. Reporting abstention as failure is how an engine gets pressured into guessing.

Pass
The evidence supports the expected result.
Fail
The observed result conflicts with the re-derived one.
Cure
The calculation establishes an obligation to the consumer.
Warning
It needs attention, and is not a failed core check.
Not applicable
The check does not apply to this loan or this fee.
Missing evidence
A required source is absent or unusable. A request, not a finding.
Manual review
The evidence is there and cannot support a deterministic answer, or your policy has not answered the question.

Part one — TRID management on the disclosure desk

The TRID & Cure Management agent sits on the disclosure desk. It watches the loan in your LOS, decides what each change means for every fee, credit and clock, and hands the analyst one action with its evidence, amount and deadline. Your LOS remains the system of record.

01
A change arrives
Fee, provider, lock, document and date changes are picked up from your LOS as they happen. Nothing changes unseen because a notification was late or lost.
02
Evidence, by your rules
Each change is tied to the documents and fields behind it. When two sources disagree, the conflict is named and settled by the source-authority rules you approved — not by whichever arrived last.
03
One case per change
Related changes become one case, linked to the fees, credits, disclosures and dates they touch. A case missing evidence says exactly what it is waiting for.
04
A decision with its working
Placement, resets, tolerance, credits, cure and deadlines are decided for what the change touched, with the rule, the evidence and the arithmetic attached.
05
The analyst decides
Approve, reject, request evidence or close, under the authority your exception matrix gives each role. Every disposition is recorded. A closed case stays closed until a person, or new evidence, reopens it.
06
Fields to the LOS, lifecycle observed
Once approved, the agent writes the LE or CD field values — sections, lines, amounts, subtotals, credits, cash to close — to your LOS through your approved field map. Your LOS then generates, issues and delivers, and the agent watches those events and reopens only the cases they affect.
Writes are all-or-nothing and verified against your LOS.

What the analyst is handed

One recommended action per case. Every action needs an analyst’s approval unless your policy authorises it to run automatically.

No action: WhenThe change moves no baseline, tolerance or clock.; What it carriesThe reason
Issue revised LE: WhenA valid reset, still inside the Loan Estimate window.; What it carriesDeadline, and the fees whose baselines reset
Issue corrected CD: WhenA reset or correction that must ride on a Closing Disclosure.; What it carriesDeadline, and whether a new three-day wait is required
Provide relief: WhenA determinate remaining cure.; What it carriesExact amount, mechanism and deadline
Complete cure actions: WhenA cure with actions still open.; What it carriesEach open action
Hold: WhenA finding your policy marks as blocking.; What it carriesThe blocking findings
Manual review: WhenThe rules cannot decide from this evidence, or your policy has not answered.; What it carriesWhat it needs to decide

Every action also carries the zero-tolerance excess, the pool excess, the lender-credit shortfall and the remaining cure, the evidence still outstanding, and whose approval it needs.

The agent owns

Every determination and the evidence behind it
The exact LE and CD field values, and the write to your LOS
Every deadline, tolerance and cure amount
Tracking each obligation through to evidenced completion

Your LOS and document systems own

Rendering the Loan Estimate and Closing Disclosure
Validation, approval and document generation
E-consent, e-sign, issuance and delivery
Generating and delivering the written provider list

Part two — independent TRID QC

The Pre-Close QC Agent runs the same decision engine independently. It rebuilds the disclosure history from source evidence, re-performs every decision, and then checks its answer against what the file concluded — never the other way round. It reviews every loan before it funds, and post-close populations on whatever cadence you set.

01
Scope and cutoff
Each review records its type, its cutoff, the population it came from and the checks in scope. The cutoff fixes what the review may see.
02
Evidence intake
Directly from your LOS — loan data and history, documents, disclosure tracking, delivery records — or from a loan package uploaded through the secure UI. Every file is kept exactly as received. Adding evidence adds to the review; it never replaces what came before.
03
Completeness
The evidence each review type requires is set against what arrived. Checks with what they need run; checks without it name exactly what is missing. A document absent from a package is not proof an event never happened, so it returns missing evidence — never a pass or a fail.
04
Timeline and fee ledger
Every value is extracted with its page, line or field. The disclosure history and the fee-by-fee ledger are rebuilt from those values — not from the LOS’s own view of the history.
05
Independent re-performance
Every decision is made again from the evidence. The lender’s prior conclusions cannot influence it.
06
Findings, then comparison
Findings come from the independent result. Every difference from what the file concluded is shown, and every agreement is recorded too.
07
Disposition and retest
The analyst confirms, rejects, corrects, requests evidence or waives where authorised. New evidence retests only what it affects, linked to the earlier result. A closed review is never rewritten.

What QC reviews, and how a finding is made

Review types

Pre-close or post-close, alone or together. A full review runs every module against one frozen evidence set.

LE-to-CD validation: What it re-performsFee identity, placement, movement and amount from first estimate to final CD.; What it returnsFee ledger, placement and amount differences, evidence gaps
WPL and provider selection: What it re-performsList timing, content, availability, listed or off-list, selection evidence.; What it returnsWPL defects, provider match, expected placement and tolerance
Changed circumstance and baseline: What it re-performsWhich estimate governed, and whether each increase had a permitted, timely, causal reset.; What it returnsFee-level baseline history, accepted and rejected increases, reasons
Tolerance, credit and cure: What it re-performsFee excess, pool excess, lender-credit shortfall, required and remaining cure.; What it returnsExact worksheets, affected fees, cure requirement
Timing and delivery: What it re-performsIssue, delivery, receipt, waiting-period, refund and corrected-disclosure deadlines.; What it returnsTrigger and due dates, the calendar used, deadline findings
Full TRID QC: What it re-performsEvery module above against one fixed evidence set.; What it returnsOne consolidated report, findings, requests and remediation status

Evidence sufficiency

An incomplete package does not produce a pass. It produces a request — and the difference between ambiguous and absent is where review time is lost.

01
Present and sufficient
The check runs and returns a result.
02
Present but ambiguous
Two sources disagree, or a value is illegible. This needs an approved source-authority rule, not more documents.
03
Absent
The check cannot run. The output is an evidence request naming the document, not a finding.

Where findings come from

Seven sources. Only the last is a comparison with the lender’s answer, and a loan may have no prior answer at all.

The disclosure itself: ExampleA transfer tax disclosed among the recording fees
Missing evidence: ExampleA revised LE with nothing to show when the borrower received it
Conflicting evidence: ExampleAn invoice and a settlement statement that disagree on one charge
An independently calculated obligation: ExampleA tolerance cure nobody cut
A timing failure: ExampleA rate-lock redisclosure sent a day late
A provider or WPL defect: ExampleA title fee held to 10% with no proof the borrower picked a listed provider
A difference from a prior conclusion: ExampleA reset the file accepted that the evidence does not support

When the file already has an answer

When the file already has an answer, the agent sets it beside its own at the right level — fee by fee, the 10% pool as a whole, credit by credit, and the cure for the loan — and shows you every difference, with the evidence on both sides.

An uncertain answer on either side is a question for a reviewer, never reported as a lender defect.
Agreement on a total proves nothing about its parts: a matching credit total can hide equal and opposite errors on two credits, so each is checked on its own.

Two ways in

Both paths run the same checks and produce the same report. The difference is how much history arrives and how findings go back. See integrations for the LOS connections.

Best fit: Direct from your LOSOngoing or high-volume review; pre-close on every loan; Package uploadTargeted reviews, low volume, or no API access
Collection: Direct from your LOSAutomatic, read-only; Package uploadAnalyst uploads the loan package
History: Direct from your LOSField history, disclosure tracking and the eFolder as retained; Package uploadWhatever versions and exports the package includes
Missing evidence: Direct from your LOSRe-read from the LOS when authorised; Package uploadAdded to the same review
Remediation: Direct from your LOSFindings and tasks written back to your LOS; Package uploadExported report, or written back to your LOS

What the report contains

Scope, cutoff and package completeness
Counts by status, severity and module
The disclosure and event timeline
The fee-by-fee ledger, first LE to final or corrected CD
WPL, provider, placement, baseline, tolerance, credit, cure and timing results
Evidence-linked findings and every analyst disposition
Exact calculation worksheets and affected amounts
Missing-evidence requests, remediation and retest status
The rule and policy versions every result was decided under
An audit trail, exportable as PDF, spreadsheet or structured data

Bring us a file. See it worked.

Every claim on this page can be checked on a loan you already have. Send one, and we will walk you through it on a call — every fee, every reset, every clock, and the page behind each.

Send us a fileMasked files are fine. How the data is handled.

01
A loan you already cured
See the cure the agent calculates, fee by fee, and where it differs from the one you paid.
02
A loan your QC flagged
Set its findings beside your reviewer’s — what it agrees with, what it adds, and what it sends back as missing evidence.
03
Your messiest disclosure history
Five revised LEs, a relabelled fee, a late provider list. See the ledger it rebuilds and the resets it accepts and rejects.

The two desks that run it

How a decision is made and proved The Loan Graph Encompass and the other integrations How the data is handled The mortgage fraud guide

Further reading on TRID

You Ain't Seen Nothin' Yet

Book a Demo

Pack up some of your complex historical files — any loan type, any investor. We run them through intake, income and condition clearing, and in 30 minutes you see every condition we created and cleared efficiently for your own team, and why.

Any loan type, any agency guideline or custom investor overlays.
Every finding cited to the guideline or document it came from

Case study highlight

Loan review fell from 4 hours 50 minutes to 47 minutes per file, and 78% of items now clear at high confidence — so QC touches only the exceptions.

Pre-Close QC Agent · Better Mortgage