Good Faith Estimate vs. Loan Estimate 2026: What Changed and What MLOs Still Get Wrong

The Good Faith Estimate (GFE) was replaced by the Loan Estimate (LE) on October 3, 2015, under the TILA-RESPA Integrated Disclosure rule (TRID). The LE is a standardized three-page form that discloses loan terms, projected payments, and closing costs. Despite being a decade-old change, MLOs still mishandle LE issuance timing and revised LE triggers regularly.

When the LE Must Be Issued

The LE must be delivered or placed in the mail no later than the third business day after receiving a complete application. A complete application under TRID requires six elements: borrower name, income, Social Security number, property address, estimated property value, and loan amount requested. The clock starts the moment all six are in hand. Waiting until the property is under contract to issue the LE is a TRID violation if the application was complete before that.

What Triggers a Revised LE

• ✦Valid changed circumstance: a change in the loan program, property value different from estimated, new information about the borrower's eligibility, or a natural disaster affecting the property
• ✦Rate lock: if the LE was issued before the rate was locked, a revised LE must be issued within 3 business days of locking
• ✦Settlement service provider changes: if the borrower chooses a different title company or settlement agent than identified on the original LE, a revised LE reflecting new costs must be issued
• ✦Borrower-requested changes: if the borrower requests a product change after LE issuance, a new LE is required

Tolerance Buckets and Cost Overruns

TRID creates three tolerance buckets. Zero tolerance covers lender fees and any affiliated settlement service: actual costs cannot exceed the LE by even $1. Ten percent tolerance covers recording fees and non-affiliated settlement services selected from a lender-provided list. Unlimited tolerance applies to services the borrower shops for independently. If zero-tolerance costs overrun, the lender must cure the excess at or before closing.