Closing Day Checklist: How to Reconcile the Closing Disclosure With Title

Reconciling the Closing Disclosure with the title company's figures often decides whether a closing goes smoothly. This checklist covers what to compare, how to review tolerance cures, which conditions to confirm, and how to schedule, as part of our closing and funding guide.

Why Does Reconciliation Matter?

Because the numbers have to match, and mismatches are expensive. When the figures on the Closing Disclosure don't line up with title, closing waits while someone reconciles them. And when fees exceed what was disclosed by more than the allowed tolerance, the lender covers the difference.

An ICE Mortgage Technology study of nearly 90,000 loans from eight lenders over six months found fee cures on more than one in three loans, averaging $1,225 per loan in cures and related expenses. The study was published in 2024 and ICE sells fee-management software, so treat it as one data point. It shows why the closing stage deserves a routine.

What Should Be in Place Before Closing Day?

• The loan has cleared to close, with underwriting conditions satisfied.
• The Loan Estimate history is complete, including any revised Loan Estimates and the Change of Circumstance records behind them.
• Title has issued its figures, including fees, prepaids, escrows, and recording costs.
• The Closing Disclosure draft is prepared from the most current figures.
• The closing is scheduled, with everyone who needs to attend confirmed.

What Does the Timing Rule Say?

The Closing Disclosure has to reach the borrower at least three business days before closing. That rule is why late changes can push a closing date, and why reconciliation should happen early. If figures change after the Closing Disclosure is issued, what is required depends on the change, so confirm with your compliance advisor whether a corrected disclosure or a new waiting period applies.

How Do You Compare the Closing Disclosure With Title?

Go line by line, not by totals. A routine that works:

1. Start with the totals. Compare the loan amount, cash to close, and any seller credits.
2. Compare each fee. Match every line on the Closing Disclosure to the title company's settlement figures: title fees, recording fees, transfer taxes, and any third-party charges.
3. Check the prepaids and escrows. Interest, insurance, taxes, and escrow deposits.
4. Check the credits. Lender credits, tolerance cures, and any adjustments.
5. Note every difference, however small, and resolve each one before moving on.
6. Record who reconciled what, and when.

When someone else can repeat the comparison from your notes and reach the same result, the routine is working.

How Do You Review Tolerance Cures?

Compare the final fees to the most recent valid Loan Estimate, fee by fee. ICE's analysis describes three categories: fees that can't increase at all, fees that can increase up to a combined 10%, and fees with no limit. Check which category each fee falls in, add up the 10% group as a category, and see whether anything exceeds what was allowed. Where a cure is owed, document it and make sure it appears correctly on the final disclosure.

If a change in circumstance justified a revised disclosure, the record should be in the file. See Disclosure Document Preparation and Tracking Services.

What Conditions Should You Confirm Before Funding?

Before the loan can move to funding, confirm that the closing conditions are complete:

• Required documents are signed and in order
• Any conditions from underwriting or the investor are satisfied
• Insurance, title, and other third-party items are in place
• Anything specific to your lender or investor is done

Keep a short list, and check each item off with a date and initials.

How Should You Prepare and Issue the Final Closing Disclosure?

Prepare it from the reconciled figures, check it against your notes, and issue it within the timing the rules require. Keep proof of delivery in the file. If the figures change again, repeat the reconciliation. Don't patch the disclosure and assume it still matches.

How Do You Coordinate and Schedule the Closing?

Confirm the date, time, and place with the borrower, title company, and anyone else involved. Confirm that everyone has the documents they need. Build in a little time before the closing for a last check of the figures. Then hand off cleanly to funding. See Mortgage Funding Day Checklist.

What Mistakes Cause Most Reconciliation Problems?

A few repeat:

• Comparing totals only, so offsetting errors hide inside matching sums
• Working from an old version of the title figures or the Loan Estimate
• Missing a revised Loan Estimate, so fees are compared with the wrong baseline
• Treating the 10% group as separate fees, instead of as a category
• Skipping the record, so nobody can tell what was checked
• Reconciling too late, leaving no time to fix a problem before the timing rule bites

Most of these come down to starting early and keeping notes.

How Does BrokerVA Handle Closing Support?

Closing is one of our five stage-based roles. Our Closing Specialists balance Closing Disclosures with title companies, review tolerance cures, prepare and issue final Closing Disclosures, coordinate and schedule loan closings, and confirm closing conditions are completed prior to funding.

Accountability for the loan stays with you, and we don't claim to prevent every error. Our goal is to lower your cost to originate by taking repeatable closing work off your team. When a client starts with us, a dedicated Coach spends a 6-week implementation period learning your processes, workflows, SOPs, and expectations, including how you reconcile and what your title companies expect. Support continues through ongoing coaching and regular check-ins.

Pricing is customized to your volume and the roles you need. We can walk through your numbers on a call and show you our cost calculator live. See how BrokerVA works.

Frequently Asked Questions

How do you reconcile a Closing Disclosure with title? Compare totals first, then each fee line against the title company's settlement figures, then prepaids, escrows, and credits. Note every difference and resolve each one, recording who reconciled what and when.

What is a tolerance cure? The refund or credit a lender provides when fees paid at closing exceed what was allowed relative to the Loan Estimate.

How far ahead must the Closing Disclosure be delivered? At least three business days before closing. If figures change after it's issued, confirm with your compliance advisor what is required.

How common are fee cures? An ICE study of nearly 90,000 loans found cures on more than one in three loans, averaging $1,225 per loan. The study is from 2024, and ICE sells fee-management software.

Sources

• ICE Mortgage Technology, Whitepaper reveals the hidden cost of mortgage fee cures (May 2024)

Want to see how your closing stage could be supported? Book a call with BrokerVA and we'll walk through your numbers and show you our cost calculator.

BrokerVA | NMLS #1977844