Tolerance cure and refund
How do we find fee tolerance violations after closing, calculate and approve the refund, and deliver it with a corrected Closing Disclosure within 60 days?
Test every closed loan's fees against its Loan Estimate of record and cure from the result. Callvu compares each charge on the Closing Disclosure with the last valid Loan Estimate by tolerance category (zero, 10 percent aggregate, no tolerance), computes any excess, routes the cure approval to compliance in the Decision Desk, refunds the borrower by the method on file, delivers the corrected Closing Disclosure with the refund, and records the cure within 60 days of consummation.
In scopeComplex: multi-party handoffsCallvu moves: classify, decide, write back
Last updated November 7, 2026.
The problem today
The 10 percent bucket was over by forty dollars, and nobody tested it until the investor did.
Fees change between the Loan Estimate and closing. Some may increase, some may not, and some may increase in aggregate by 10 percent. The test is mechanical but depends on knowing which Loan Estimate was the valid baseline for each fee, which changed circumstances reset which charges, and the category of each fee. Done by hand at closing, under time pressure, it is skipped; found later, it is a refund plus a corrected disclosure within 60 days, or a violation.
The investor's and the examiner's test is the same test, run later. A lender that runs it on every loan at closing and again after cures its own violations in time.
The baseline is in the record if the changed-circumstance process kept it.
How it runs
From the requestto the system of record.
A loan closes (or the post-closing review flags fees). Callvu runs the tolerance test on the Closing Disclosure of record against the Loan Estimate of record for each charge.
- Post-closer
- Sees the test results; no longer compares by eye.
- Compliance
- Approves the cure and the corrected disclosure in the Decision Desk.
- Borrower
- Receives the refund and the corrected Closing Disclosure.
- Callvu
- Tests, computes, routes, refunds, delivers and records within the window.
Classify the baseline and the categories
For each charge, the valid baseline is identified (the initial Loan Estimate or the last revised Loan Estimate that validly reset that charge under the changed-circumstance record) and the tolerance category is applied: zero tolerance (lender charges, affiliate charges, transfer taxes, services the consumer could not shop for), 10 percent aggregate (recording fees and services from the lender's list the consumer could shop for), or no tolerance (prepaid interest, escrow, insurance, services the consumer shopped for off the list).
Test and compute
Each charge on the Closing Disclosure is compared with its baseline under its category; the zero-tolerance excesses and the 10 percent aggregate excess are computed, and the total cure amount is set. The test result is recorded whether or not there is an excess.
Decide
A cure amount goes to compliance in the Decision Desk with the test, the baseline and the changed-circumstance record, and only the allowed outcomes: approve the refund, correct the baseline (where a valid revised Loan Estimate was not applied), or dispute with reasons. The decision is recorded.
Refund, disclose and write back
The refund is paid to the borrower by the method on file, the corrected Closing Disclosure reflecting the refund as a lender credit is delivered by the consented method, both within 60 days of consummation, and the test, the decision, the refund and the disclosure are written to the LOS.
Where it ends: Every closed loan's fees were tested against the right baseline, every excess was cured with a refund and a corrected disclosure inside the 60 days, and the test result is on the record for the loans with no excess too. The Decision Trace shows the baseline, the categories and the computation; the Audit Trace shows the decision, the refund and the delivery.
Runtime enforcement
What is enforcedwhile the work runs.
The regulations preloaded in Callvu Studio and the bank's own policies, applied as steps that run, not lines in a binder. A step that breaks a rule does not run, so a completed run was compliant.
The handoff
Between the front doorand the back office.
The front door
Closing and the post-closing review; the borrower meets the process in the refund and the corrected disclosure.
The back office
Compliance approves cures from a computed test; the post-closer stops comparing by eye.
The Decision Desk
- A cure amount goes to compliance in the Decision Desk with the test and the changed-circumstance record, and only approve the refund, correct the baseline, or dispute with reasons.
Proof
In scope.Proof at scale, not one process at a time.
The kind of process Callvu runs in production for customers in this industry. Ask for a reference on this exact process. The results below are the industry's published proof; each claim code links to its record on agents.callvu.com.
Questions
What buyers ask next,answered plainly.
Which Loan Estimate is the baseline?
For each charge, the initial Loan Estimate or the last revised Loan Estimate that validly reset that charge under the changed-circumstance record. The test identifies it per charge.
How fast must a cure go out?
The refund and the corrected Closing Disclosure within 60 days after consummation; the clock is tracked from consummation.
Is every loan tested?
Yes, at closing and again at the post-closing review, with the result recorded whether or not there is an excess.
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