What Is Loan Fee Rebilling and How Should You Address Charges After Closing?

Loan fee rebilling happens when a lender, servicer, title company, or third party posts additional fees after you thought a loan was final. These charges may be legitimate—such as a belated third‑party invoice for an appraisal or recording—or they can result from accounting errors, missing disclosures, or misapplied payments.

In my 15 years working with borrowers and mortgage teams, I’ve seen rebilling range from harmless bookkeeping adjustments to confusing, avoidable charges that could have been caught and corrected earlier. Below I explain why rebills happen, how to verify them quickly, what consumer protections may apply, and step‑by‑step actions to resolve or contest an unexpected post‑closing charge.

Why loan fee rebilling occurs

Common causes include:

  • Late third‑party invoices. Appraisers, surveyors, or local recording offices may bill after closing when paperwork arrives late.
  • Post‑closing reconciliation. Lenders sometimes reconcile amounts after funds move and find small differences that prompt a rebill.
  • Escrow or property‑related adjustments. Insurance or tax changes that are applied to escrow accounts can create new charges.
  • Data entry or accounting mistakes. Human or system errors can create duplicate or incorrect bills.
  • Fees omitted or marked “estimated” on the Closing Disclosure. Some estimated third‑party fees can change after closing.

Each cause has a different remedy. The first step is always documentation: obtain the bill and compare it to the Closing Disclosure, settlement statement, and your loan documents.

What protections apply and where to look

Key protections and rules you should check:

  • TRID and the Closing Disclosure: For most mortgage loans, the TILA‑RESPA Integrated Disclosures (TRID) rule requires a Closing Disclosure that shows final costs. Some charges have strict tolerance limits; others can change. See CFPB guidance on loan disclosures for details (Consumer Financial Protection Bureau). CFPB: Closing Disclosure and TRID guidance.
  • RESPA (Regulation X): Escrow account rules and certain servicing practices are governed by RESPA. If the charge relates to an escrow analysis or servicing error, RESPA protections may apply.
  • State consumer protection laws and licensing: State regulators can help with disputed fees, especially with licensed mortgage lenders or title companies.

If a post‑closing charge was never disclosed or contradicts the Closing Disclosure, it may violate disclosure rules or tolerance limits. Always request a written explanation.

Immediate steps to take when you receive a rebill (practical checklist)

  1. Don’t ignore the notice. Even if you believe the charge is wrong, ignoring a bill can create additional fees or impact your credit.
  2. Gather documents. Pull your Closing Disclosure, final settlement statement (sometimes called the HUD‑1 for older loans), cashier’s checks, bank statements, and any communications from the lender or title company.
  3. Ask for an itemized invoice. Request in writing a clear breakdown of the charge, what it covers, and the date it was incurred.
  4. Compare line‑by‑line. Match the invoice to items on the Closing Disclosure. Mark fees that were disclosed as “estimated,” not shown, or that exceed disclosure tolerances.
  5. Ask for correction or refund. If the charge is an error, request reversal and refund in writing. Include copies of evidence.
  6. Escalate if needed. If the lender or servicer won’t correct a clear error, file a complaint with the Consumer Financial Protection Bureau and your state banking or mortgage regulator.
  7. Keep records. Save every email, letter, and call log. Note names, dates, and what was promised—this helps regulators and can be vital if you must dispute on credit reports.

How to phrase your dispute (short template)

Use plain language and include facts. A short, effective dispute letter contains:

  • Your name, loan number, and contact info.
  • The date you noticed the charge.
  • A clear statement that you dispute the charge with the dollar amount and reason (e.g., “Fee not disclosed on Closing Disclosure” or “Duplicate charge”).
  • A request for an itemized explanation or refund and a deadline to respond (typically 30 days).
  • Copies (never originals) of supporting documents.

In many cases, an organized written request moves the servicer to research and resolve the problem faster than phone calls alone.

When a rebill may be valid

Not all rebills are improper. Valid scenarios include:

  • A third‑party billed after closing for a service that the borrower authorized and that wasn’t final at closing.
  • Small reconciliations tied to escrow shortages after an annual escrow analysis.
  • Fees expressly permitted by the loan agreement or state law.

If the charge is valid, ask for a detailed explanation of why it was not included at closing and whether it could have been avoided. If the amount is modest, you may choose to pay and request an explanation for record‑keeping; for larger items, push for a detailed accounting and consult a housing counselor or attorney.

When to involve regulators or third parties

  • CFPB complaints: The Consumer Financial Protection Bureau collects complaints and often prompts responses from companies. Use the CFPB complaint portal if the company fails to resolve a clear error. (CFPB: consumerfinance.gov)
  • State regulator or attorney general: For licensed lenders or title companies, state agencies can accept complaints and enforce rules.
  • HUD housing counselors: HUD‑approved counselors can advise on mortgage issues and dispute options.

Real‑world examples and lessons learned

Example 1: Late appraisal invoice. A borrower received a $350 invoice two weeks after closing for an appraisal that was performed prior to closing but billed late by the appraiser. The creditor reversed the rebill after the borrower provided the Closing Disclosure and proof the service had been paid at closing.

Example 2: Escrow shortage surprise. A homeowner saw an increase on their first post‑closing mortgage statement due to an escrow shortage driven by a sudden spike in property taxes. The servicer provided an escrow analysis explaining the shortage and offered repayment options rather than immediate collection.

Example 3: Duplicate recording fee. A county charged a recording fee twice due to a clerical mistake. The borrower documented the payments and worked with the title company and county to obtain a refund.

These scenarios show why documentation at closing and prompt follow‑up matter.

Tips to avoid rebilling before and at closing

  • Review your Closing Disclosure carefully before closing. Flag any fees listed as “estimated.” (See our guide on Closing Disclosure.)
  • Ask who controls each third‑party fee—if the lender didn’t select the vendor, that fee can sometimes change.
  • Keep copies of any checks or wire confirmations used at closing.
  • Request a post‑closing reconciliation or confirmation of final fees in writing if any costs were listed as estimates.

Related reading: see our articles on the Closing Disclosure, Reconciliation of Closing Disclosure, and How lender fees are allocated during mortgage closing for practical checklists and examples.

When to get professional help

If the charge is large, the lender refuses to correct a clear error, or you suspect deceptive practices, consider:

  • Contacting a HUD‑approved housing counselor for low‑cost advice.
  • Hiring a consumer attorney experienced in mortgage/real estate disputes.
  • Consulting your state banking department about licensing violations.

In my practice, involving a housing counselor or attorney early often leads to faster, cleaner resolutions—especially where multiple parties (lender, title company, county recorder) are involved.

Practical timeline and expectations

  • Immediate (0–7 days): Request an itemized invoice and compare with Closing Disclosure.
  • Short term (7–30 days): Expect a written response from the lender or servicer. If they agree it’s an error, expect a refund or reversal within a billing cycle.
  • Longer term (>30 days): If unresolved, file a CFPB complaint and contact your state regulator. Keep pursuing documentation and consider legal help for material sums.

Final checklist before you act

  • Do you have a copy of your Closing Disclosure and final settlement statement? If not, request them.
  • Is the charge itemized and dated after closing? Ask for proof the service was performed after closing.
  • Was the charge disclosed as “estimated” or omitted entirely? Note that distinction when you dispute.
  • Have you put your dispute in writing and kept copies? Written records matter.

Professional disclaimer

This article is educational and informational only. It does not constitute legal, tax, or financial advice. For advice tailored to your situation, consult a qualified attorney, housing counselor, or financial professional.

Authoritative sources

If you want, I can draft a short dispute letter template you can copy and customize for your situation, or help you identify the specific regulator in your state based on the company name on the bill.