Mortgage Fees: Aggregate Increases

Estimated reading time: 1 minute

The CFPB explains that some mortgage closing charges share a 10% aggregate increase limit. This is not a separate allowance for every charge or the entire closing bill.

Fictional covered mortgage: the complete basket contains $100 recording fees and $900 for a required, shoppable service from an unaffiliated provider selected from the lender’s written list. Assume no valid revised estimate or other exception changes the baseline.

The estimated basket is $1,000. Its 10% allowance is $100, making the comparison ceiling $1,100.

Scenario A: recording rises to $150 while the service stays $900. Although recording rose 50%, the basket totals $1,050, only 5% higher. This basket has no excess above its ceiling.

Scenario B: recording is $150 and the service $1,000. The $1,150 total exceeds the ceiling by $50, not the full $150 increase.

Ask the lender to verify which charges belong together, the governing estimate and any refund due. Other cost categories follow different rules; this exercise does not validate the whole closing disclosure.