This comparison table outlines key differences between Closing Disclosure Section A and Section B for mortgage closing teams. It is designed to help you cross-verify line items against your pre-closing folder, avoid disclosure errors that can trigger mandatory waiting period resets, and align entries with TILA-RESPA Integrated Disclosure (TRID) requirements. All guidance is for educational use only; always confirm disputed entries with your loan originator or licensed closing agent, and reference Margin Desk supporting process sheets for folder organization best practices if needed.
Section A Origination Charge Entry Boxes
Section A contains only charges imposed directly by your lender or mortgage broker for the work of originating your loan, with no third-party fees permitted in this section. All entries here are subject to zero-tolerance variance rules, meaning the final amount listed cannot be higher than the amount disclosed on your initial or most recent revised Loan Estimate, unless a documented borrower-initiated change or qualifying changed circumstance applies. Each entry box is pre-populated by the lender’s loan origination system, and manual adjustments to these boxes require a signed change form from both the borrower and loan originator to be retained in the closing file. Common entry boxes in this section include origination points paid to reduce the loan’s interest rate, lender underwriting fees, lender processing fees, and mortgage broker fees if a broker is involved in the transaction. Any lender credit applied to origination costs will appear as a negative number in the corresponding Section A box, with a cross-reference to the lender credit line on page 3 of the CD. Illustrative example: if a borrower agrees to a 0.75% origination fee on a $400,000 loan, the Section A origination fee entry box will show $3,000, with no hidden add-ons or unlisted fees permitted in this section.
Section B Non-Shoppable Service Line Rows
Section B lists all third-party services required by the lender that the borrower is not permitted to shop for, per CFPB TRID guidelines. These services are selected exclusively by the lender, either because the lender has an exclusive contract with the provider or because the lender prohibits borrower selection for that specific service to ensure loan eligibility. Like Section A charges, Section B fees are subject to zero-tolerance variance rules, with no increases permitted unless a valid changed circumstance is documented in the closing file. Each line row in this section includes the full name of the service, the name of the selected provider, and the exact dollar amount of the charge, with all providers listed in the Service Provider List on page 4 of the CD. Common line items here include appraisal fees from a lender-selected appraisal management company, credit report fees from a lender-approved credit reporting agency, flood determination fees, tax monitoring fees, and tax status research fees. A common classification error to avoid is placing borrower-selected service fees in Section B; any service the borrower is allowed to shop for must be listed in Section C of the CD, even if the borrower chooses a provider from the lender’s recommended list. Illustrative example: a $425 appraisal fee ordered directly by the lender from their approved vendor will appear as a line row in Section B, even if the full cost is passed through to the borrower at closing.
Disclosure Cross-Reference Annotated Footnotes
All standard CD forms include required footnotes that cross-reference Section A and Section B entries to other parts of the disclosure and supporting loan documents, with four core annotations applicable to these sections:
- All Section A charges are matched to the corresponding line items on the most recent signed Loan Estimate; any variance greater than $0 requires a revised Loan Estimate to be issued at least 3 business days prior to closing, unless a documented exception applies per 12 CFR § 1026.19(e).
- All Section B service providers are confirmed to be on the lender’s official approved non-shoppable provider list, with charges matched exactly to the corresponding Loan Estimate Section B line items; no variance is permitted without a signed changed circumstance form retained in the closing file.
- Any lender credit applied to Section A or Section B charges must be explicitly listed in the Lender Credits line item on page 3 of the CD, with a corresponding cross-reference to the specific line item the credit is intended to cover. Credits cannot be contingent on unstated loan terms or post-closing borrower actions.
- Misclassification of fees between Section A and Section B, such as listing a third-party appraisal fee in Section A or an origination fee in Section B, requires a revised CD to be issued prior to closing. Uncorrected misclassifications can result in mandatory full refunds of the misclassified fee to the borrower within 60 days of closing per CFPB enforcement guidelines.
Required Supporting Document Attachment Checklist
Use the table below to organize supporting documentation for Section A and Section B entries in your closing folder, with all documents retained for a minimum of 3 years post-closing per regulatory requirements.
| Document Name | Applies to Section A | Applies to Section B | File Folder Location | Verification Step |
|---|---|---|---|---|
| Signed Loan Estimate Acknowledgment | Yes | Yes | Closing Disclosures Tab | Confirm 3-business-day waiting period was met, and all disclosed Section A and B charges match final CD entries exactly |
| Signed Origination Fee Agreement | Yes | No | Loan Origination Tab | Verify agreed origination points, underwriting fees, and processing fees match Section A entry box amounts with no unapproved add-ons |
| Appraisal Invoice + Lender Order Confirmation | No | Yes | Third-Party Services Tab | Confirm appraisal fee matches Section B line item, and appraisal was ordered exclusively by the lender with no borrower input on provider selection |
| Credit Report Invoice from Lender-Selected Provider | No | Yes | Third-Party Services Tab | Cross-reference credit report charge to Section B line item, confirm no secondary credit report fees are listed in either section |
| Signed Lender Credit Approval Letter | Yes | Yes | Loan Approval Tab | Confirm any agreed lender credits are applied correctly to Section A or B charges as outlined in the formal approval terms |
All documents must be dated within 30 days of closing, and any discrepancies between supporting documents and CD entries must be resolved at least 48 hours prior to the scheduled closing date to avoid delays.
Post-Closing Verification Completion Checkboxes
Complete the following checks during your post-closing file audit to ensure compliance with TRID requirements and avoid regulatory penalties:
- [ ] All Section A charges are verified to match the signed origination fee agreement, with no unapproved add-ons or variances from the final revised Loan Estimate
- [ ] All Section B service providers are confirmed to be on the lender’s official non-shoppable provider list, with no borrower-selected services incorrectly listed in this section
- [ ] All variances between Loan Estimate and CD Section A and B entries are documented with a signed changed circumstance form from the loan originator and borrower
- [ ] The combined total of Section A and Section B charges is correctly rolled up to the Loan Costs subtotal on page 2 of the CD, with no arithmetic errors
- [ ] All supporting documents listed in the attachment checklist are filed in the correct folder tab, and full copies are provided to the borrower with their final closing packet
Next action: Pull your current closing folder’s draft CD and cross-reference Section A and B line items against the checklist above to resolve any discrepancies 48 hours before your scheduled closing.