Closing Disclosure in Texas: What Can Still Change Before You Sign

Your Closing Disclosure (CD) arrives at least three business days before your scheduled closing date, per federal TRID rules. It looks like the final word on your transaction. Several line items can still shift between the day you receive it and the moment you sign at the table. Knowing which ones can change, and why, keeps you from being caught off guard on one of the biggest days of a home purchase.

This is a real scenario Austin buyers encounter: the CD arrives Wednesday for a Monday closing, the title company catches a proration error on Thursday, and by Friday morning the cash-to-close number has changed. Here’s what to watch for and how to stay prepared.

What the Closing Disclosure Actually Is

The Closing Disclosure replaced the old HUD-1 Settlement Statement in 2015 under the TILA-RESPA Integrated Disclosure (TRID) rules. It’s a five-page document that shows your loan terms, monthly payment breakdown, closing costs by category, and cash to close. Your lender must deliver it at least three business days before closing, and if certain terms change significantly, a new CD may be required, restarting the three-day clock.

Understanding the structure helps you spot errors. Page 1 summarizes your loan terms and projected payments. Pages 2 and 3 break down closing costs in detail. Page 4 covers loan disclosures and escrow account information. Page 5 shows loan calculations and contact information.

Items That Can Still Change After the CD Is Issued

Federal law distinguishes between changes that require a new three-day waiting period and changes that don’t. Here are the items that can shift without resetting the clock:

• Prepaid interest: Calculated based on the exact number of days between closing and your first payment. If closing shifts by one day, this number changes.
• Homeowner’s insurance premium: Your insurer may update the policy premium right before closing. Verify the final figure with your insurance agent a few days out.
• Prorated property taxes: In Texas, property taxes are paid in arrears. The proration between seller and buyer at closing is calculated based on the actual closing date. Move the date and the split moves.
• HOA dues and prorations: If the property is in an HOA, dues are prorated to the day of closing. If the HOA raised dues shortly before closing, this figure can change.
• Final payoff amount on seller’s existing mortgage: Payoff figures are good for a limited window. If the seller’s lender updates it right before closing, the seller’s net proceeds change but certain shared costs can shift too.
• Survey fee: If a new survey was ordered later than expected, the final invoice amount can vary slightly from the estimate.

For a broader look at the timeline between contract and closing, see our guide to title, escrow, and closing in Texas, which walks through each party’s role in the process.

Changes That Require a New Three-Day Wait

If these specific items change after the CD is issued, federal law requires the lender to send a revised CD and restart the three-day clock before closing can proceed:

• APR increase of more than 0.125%: If your annual percentage rate goes up by more than this threshold, you get a new CD.
• Loan product change: Switching from a fixed-rate to an adjustable-rate loan (or vice versa) triggers a new CD.
• Prepayment penalty added: If a prepayment penalty appears on the final CD that was not on the Loan Estimate, you get a new CD and the clock restarts.

These changes are uncommon in a standard transaction, but they do happen. Last-minute rate lock expirations, lender errors, or borrower-requested changes can trigger them. If it happens to you, ask your lender for the revised CD in writing immediately so you know exactly how your three days restart.

How to Compare Your CD to Your Loan Estimate

You received a Loan Estimate (LE) early in the process. One of the most important things you can do when the CD arrives is compare it line by line against your LE. The tolerance rules under TRID limit how much certain fees can increase:

• Zero tolerance: Fees from your lender (origination charges, points, transfer taxes) cannot increase at all from LE to CD.
• 10% tolerance: Recording fees and third-party services you didn’t shop for (like the appraisal) can increase up to 10% in aggregate.
• Unlimited tolerance: Prepaid items, initial escrow payments, and services you shopped for yourself can change without limit.

If a zero-tolerance fee increased on your CD and your lender can’t justify it, they’re required to cure the difference, meaning they absorb the overcharge. The Austin real estate market moves fast, but this is worth slowing down to verify before you wire funds.

Three Things That Trip Up Austin Buyers Most Often

Cash to close: This is the number that requires a cashier’s check or wire transfer on closing day. Verify it with your title company the business day before closing. Title companies in Travis County typically provide a final confirmation 24 to 48 hours before your closing appointment. Compare that number to the CD you received and flag any discrepancy over $50.

Property tax escrow setup: Texas has no state income tax but compensates with higher property taxes. Lenders set up your escrow account based on the current year’s estimated tax, which may differ from the actual tax if the home’s appraised value recently changed. Verify that the escrow cushion in your CD reflects reasonable numbers for your Travis County, Williamson County, or Hays County tax rate. For context on Austin-area property taxes, see our overview at Austin FHA loan limits and lender qualification.

Loan terms: Confirm the rate, term (30 years vs. 15 years), and product type (fixed vs. ARM) on the CD matches exactly what you agreed to when you locked. Rate lock mistakes are rare but they do occur, and catching one early is far easier than catching it at the table.

When to Ask for a Delay

You have the right to request a closing delay if you receive a revised CD with significant changes and need time to understand them. This is especially true if your cash-to-close changes by more than $1,000 without a clear explanation, if your rate or loan product changed unexpectedly, or if fees that were zero-tolerance on your Loan Estimate increased on the CD. A one-day delay is far better than signing documents you don’t fully understand.

For reference on what a complete CD should look like alongside your Loan Estimate, see our overview of the key documents in a Texas home purchase.

Frequently Asked Questions

Can my mortgage rate change after I receive the Closing Disclosure?

If your rate is locked and the lock is still valid, your rate should not change. If your APR increases by more than 0.125% after the CD is issued, federal TRID rules require the lender to issue a revised CD and restart the three-business-day waiting period. Always confirm your locked rate and its expiration date as you approach closing.

How much can closing costs change between my Loan Estimate and Closing Disclosure?

Fees from the lender (origination, discount points) have zero tolerance, meaning they cannot increase at all. Third-party fees for services you didn’t shop for have a 10% aggregate tolerance. Services you shopped for yourself have unlimited tolerance. If zero-tolerance fees increased on your CD, the lender is required to absorb the difference.

When exactly do I get my Closing Disclosure in Texas?

Under federal TRID rules, your lender must deliver the CD at least three business days before closing. In Texas, most title companies coordinate with lenders to issue CDs within 3 to 5 business days before the closing date. If the CD is delivered late, your closing date must be pushed to comply with the three-day rule.

What if my cash-to-close amount is different from what I expected?

Verify the final cash-to-close figure with your title company the business day before closing. Common reasons for a higher-than-expected number include property tax proration adjustments, homeowners insurance premium changes, or HOA proration changes. If the difference is larger than a few hundred dollars and you can’t identify the source, ask your loan officer for an itemized explanation before you wire funds.

Do I sign the Closing Disclosure before closing day?

You sign the Closing Disclosure at the closing table as part of your loan package, not before. The three-day waiting period is measured from when the lender delivers the CD to you, not from when you sign it. You have time to review it carefully, ask questions, and verify numbers before showing up to sign.

Can my property tax escrow amount change after closing?

Yes. Your lender estimates escrow based on current year tax figures, but the county can reassess property values after closing, which may increase your required escrow payment at the next annual escrow analysis. In Travis County, appraisal notices typically go out in spring, and values can change significantly year over year. Budget for potential escrow adjustments in year two and beyond.

Questions about where you stand in the process or what your Closing Disclosure should look like for your specific loan? Schedule a discovery call and we’ll walk through it together, no pressure, no commitment, just clarity.

Ferrando Financial LLC | NMLS# 2403080 | Licensed in Texas. This content is for educational purposes only and does not constitute a commitment to lend. Loan approval is subject to credit, income, and property qualification. Federal TRID disclosure rules are subject to regulatory updates; confirm current requirements with your lender.