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

*TRID and cure management*

> How Sei’s agents classify every fee, test every reset, compute tolerance, lender-credit shortfall and cure, track every clock — and re-perform it all as QC.

**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.

## 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](/how-it-works) behind it.

## The mechanics, rule by rule

### 1. 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”

### 2. 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

### 3. 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

### 4. 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

### 5. 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

### 6. 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

### 7. 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

### 8. 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

### 9. 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

- **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](/platform/loan-graph) holds the facts. Documents are read by [Document Intelligence](/platform/document-intelligence), every value carrying the page or field it came from.

## Seven outcomes, and why abstaining is one of them

- **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](/for-lenders/trid-and-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](/integrations) remains the system of record.

### 1. 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.

### 2. 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.

### 3. 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.

### 4. 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.

### 5. 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.

### 6. 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

| Action | When | What it carries |
| --- | --- | --- |
| No action | The change moves no baseline, tolerance or clock. | The reason |
| Issue revised LE | A valid reset, still inside the Loan Estimate window. | Deadline, and the fees whose baselines reset |
| Issue corrected CD | A reset or correction that must ride on a Closing Disclosure. | Deadline, and whether a new three-day wait is required |
| Provide relief | A determinate remaining cure. | Exact amount, mechanism and deadline |
| Complete cure actions | A cure with actions still open. | Each open action |
| Hold | A finding your policy marks as blocking. | The blocking findings |
| Manual review | The rules cannot decide from this evidence, or your policy has not answered. | What 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](/for-lenders/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.

### 1. 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.

### 2. 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.

### 3. 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.

### 4. 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.

### 5. Independent re-performance

Every decision is made again from the evidence. The lender’s prior conclusions cannot influence it.

### 6. Findings, then comparison

Findings come from the independent result. Every difference from what the file concluded is shown, and every agreement is recorded too.

### 7. 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.

### Review types

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

### Evidence sufficiency

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

### Where findings come from

| Source | Example |
| --- | --- |
| The disclosure itself | A transfer tax disclosed among the recording fees |
| Missing evidence | A revised LE with nothing to show when the borrower received it |
| Conflicting evidence | An invoice and a settlement statement that disagree on one charge |
| An independently calculated obligation | A tolerance cure nobody cut |
| A timing failure | A rate-lock redisclosure sent a day late |
| A provider or WPL defect | A title fee held to 10% with no proof the borrower picked a listed provider |
| A difference from a prior conclusion | A 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

|  | Direct from your LOS | Package upload |
| --- | --- | --- |
| Best fit | Ongoing or high-volume review; pre-close on every loan | Targeted reviews, low volume, or no API access |
| Collection | Automatic, read-only | Analyst uploads the loan package |
| History | Field history, disclosure tracking and the eFolder as retained | Whatever versions and exports the package includes |
| Missing evidence | Re-read from the LOS when authorised | Added to the same review |
| Remediation | Findings and tasks written back to your LOS | Exported 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.

- **A loan you already cured** — See the cure the agent calculates, fee by fee, and where it differs from the one you paid.
- **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.
- **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.

Masked files are fine. [How the data is handled](/security). [Send us a file](/contact-us).

## The two desks that run it

- **TRID & Cure Management** (/for-lenders/trid-and-cure-management) — Watches every disclosure clock, tracks fee tolerance and changed circumstance, and cuts the cure before it becomes a finding.
- **Pre-Close QC Agent** (/for-lenders/pre-close-qc-agent) — Pre-close quality control on every loan, with agency- and investor-ready audit trails.

## Further reading on TRID

- [The Three Tolerance Buckets: Balancing the Closing Disclosure Against the Loan Estimate With an AI Agent](/blog/trid-fee-tolerances-closing-disclosure-cures-ai-mortgage)
- [The Disclosure Desk: Change of Circumstance, the Redisclosure Clock, and What an AI Agent Is Allowed to Reset](/blog/disclosure-desk-change-of-circumstance-redisclosure-ai-mortgage)
- [TRID Compliance with AI Agents: The Six-Element Trigger, the 3/7-Day Clocks, and Re-Disclosure](/blog/trid-loan-estimate-closing-disclosure-ai-agents-timing)
- [Mortgage QC at 100% Coverage: What Changes When AI Reviews Every Loan Instead of a 10% Sample](/blog/ai-mortgage-quality-control-pre-funding-post-close-100-percent-coverage)
- [AI Agents Inside the LOS: The System-of-Record Boundary, the Write-Back Discipline, and the Audit Trail That Survives an Exam](/blog/ai-agents-inside-the-los-system-of-record-boundary-write-back-mortgage)
- [How Long the Agent's Evidence Has to Live: Retention Clocks for AI Mortgage Records Under Reg B, Reg Z, and Reg C, and the Default That Deletes Your Proof](/blog/ai-mortgage-agent-recordkeeping-retention-ecoa-trid-audit-trail)

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_Source: [https://www.seiright.com/blog/guides/trid-and-cure-management](https://www.seiright.com/blog/guides/trid-and-cure-management) · Sei AI_