Which Loan Estimate Services You Can Shop For

The short answer

Look at Section C, “Services You Can Shop For,” on page 2 of your Loan Estimate. Those are the lender-required third-party services for which that lender permits you to choose a provider. Use the separate written provider list, confirm any off-list provider with your loan officer early, and compare quotes for the same scope.

That answer is deliberately tied to your form. Not every third-party service is shoppable, and a service that one lender permits a borrower to shop may be handled differently by another lender or in another transaction. The controlling starting point is the way the service appears on the Loan Estimate you received.

Start with Section C on page 2

The CFPB's consumer explainer on shoppable closing services directs borrowers to Section C of page 2. Its heading is “Services You Can Shop For.” Under Regulation Z § 1026.37(f)(3) and its official interpretation, this section contains services the creditor requires in connection with the loan, that a third party other than the creditor or mortgage broker will provide, and for which the creditor permits the consumer to shop.

Section B, “Services You Cannot Shop For,” is different. It covers lender-required third-party services for which the creditor does not permit the borrower to select the provider. The Loan Estimate rule gives possible examples for both sections, but examples are not a promise that a particular charge will always appear in B or always appear in C. Read the label and line item on your disclosure.

The same distinction also explains why “third-party charge” and “shoppable charge” are not synonyms. A credit report, appraisal-related service, flood determination, title service, pest inspection, survey, or closing service might involve someone outside the lender. That alone does not give the borrower the right to select the provider. Section C identifies the lender-required services the lender actually permits you to shop for in that transaction.

The written provider list is a separate document

If the creditor permits you to shop for a required settlement service, Regulation Z § 1026.19(e)(1)(vi) requires a separate written list. The list must identify at least one available provider for every service shown as shoppable and state that you may choose a different provider. “Available” matters: the official interpretation says the identifying information must let the consumer contact the provider, and the named provider must serve the relevant consumer or property location.

The list is a companion to the Loan Estimate, not part of the three-page form. It may arrive in the same email, portal package, or envelope, so save both documents together. The Appendix H model forms include model form H-27 for this written list.

What to check on the list

• Match every service described as shoppable on Section C to a corresponding service on the written list.
• Check that at least one provider is identified for each of those services.
• Look for usable contact information and confirm that the provider serves the property location.
• Read the statement explaining that you may select another provider.
• Keep the list with the version of the Loan Estimate delivered at the same time.

If you cannot locate the list, ask the loan officer where it appears in the disclosure package. That is a practical request for the document; it is not a conclusion that a disclosure violation occurred.

You may propose a different provider, subject to reasonable requirements

The official rule says a creditor permits shopping when the consumer may select the provider, subject to reasonable requirements. The official interpretation gives appropriate licensing for a settlement agent as one example. It also makes clear that forcing a consumer to choose only from the creditor's list is not shopping for purposes of this rule. The CFPB's consumer guidance puts the point plainly: you may be able to use a provider that is not listed as long as the lender agrees to work with that provider.

That does not mean any provider must be accepted automatically. A provider may need the right license, authority, geographic coverage, insurance, security process, capacity, or ability to satisfy transaction-specific instructions. The regulatory text supports reasonable qualification requirements; the operational details are practical questions for the lender and provider.

Compare identical scopes, not just totals

A price is useful only when it covers the work your transaction requires. Ask each provider to describe the same service line by line. One quote may bundle searches, endorsements, document preparation, delivery, wire, courier, or closing tasks that another quote separates or omits. Similar labels can hide different scopes.

Use the Section C description and the lender's requirements as the common baseline. Then ask each provider for a written itemization that identifies what is included, what may be billed separately, how long the quote remains current, and what facts could change it. Ask the loan officer whether the proposed scope satisfies the lender's requirements. Shopping creates a choice and a comparison opportunity; it does not guarantee a lower final charge.

A simple comparison method

1. Copy the exact Section C service name into your notes.
2. Ask the loan officer what work or deliverables that service must include.
3. Request written quotes using the same property and transaction facts.
4. Place included tasks, exclusions, possible add-ons, and timing side by side.
5. Confirm provider eligibility and scope with the loan officer before selecting.

Provider-choice timing: what the rule says and what to ask

The disclosure timing rule is specific. For a covered transaction, the creditor generally must deliver or mail the Loan Estimate no later than the third business day after receiving the application, and the separate written provider list follows the timing requirements for that disclosure. That is the creditor's disclosure deadline.

The cited sources do not establish one universal deadline by which every borrower must finish selecting an off-list provider. Closing schedules, title or settlement practices, provider onboarding, lender review, appraisal or inspection access, and other file-specific needs can affect the workable choice date. Treat those as practical constraints, not as a made-up federal deadline.

Ask early: “What is the latest date by which you need my provider selection, and what must that provider submit to be approved and coordinated?” If you are considering someone outside the written list, share the business name and contact information promptly. Waiting until the final days may leave too little time for review or performance even when the provider is otherwise qualified.

How provider choice may affect tolerance treatment

In this context, a “tolerance” is part of Regulation Z's good-faith framework for comparing certain estimated charges with actual charges. It is not a promise that a provider's price cannot change, and it is not a blanket cap on every closing cost.

When the creditor permits shopping and the consumer either does not select a provider or selects an unaffiliated provider from the creditor's written list, eligible charges generally fall into the rule's aggregate 10-percent category. “Aggregate” is important: the comparison applies to the total of the covered charges, not a separate 10-percent ceiling on each individual line. Other conditions and any permitted revised estimate can matter.

When the consumer chooses a qualified provider that is not on the written list, § 1026.19(e)(3)(iii) generally treats that charge differently. The actual off-list fee is not compared with the original estimate under the zero- or 10-percent categories, so long as the original estimate was based on the best information reasonably available to the creditor. That change in treatment is not a penalty and does not predict whether the final charge will be higher or lower.

The Closing Disclosure rule at § 1026.38 also separates “Services Borrower Did Not Shop For” from “Services Borrower Did Shop For.” A service originally listed as shoppable on the Loan Estimate is generally shown as not shopped on the Closing Disclosure when the borrower uses a provider from the written list, and as shopped when the borrower selects one outside that list. That later classification records what happened; it does not rewrite the original Section C permission.

Tolerance analysis is technical and fact-specific. Ask the creditor to explain how a provider choice affects the particular line items on your disclosures. This article is educational and is not legal advice.

Borrower checklist before choosing a provider

• Find Section C on page 2 of your current Loan Estimate.
• Locate the separate written provider list delivered with it.
• Match the service descriptions between the two documents.
• Ask what qualifications an off-list provider must meet.
• Ask for the file-specific selection and coordination deadline.
• Compare written quotes for identical work, exclusions, and timing.
• Confirm the selected provider with the loan officer in writing.
• Keep the estimate, provider list, quotes, selection confirmation, and later Closing Disclosure together.
• Review whether the Closing Disclosure shows the service under “did shop” or “did not shop,” and ask about anything unexpected.

Useful questions for your loan officer and provider

Questions for the loan officer

• Which exact Section C services may I shop for on this Loan Estimate?
• Where is the corresponding written provider list?
• What reasonable qualifications must another provider meet?
• Who confirms that an off-list provider is acceptable?
• What date do you need my selection, and what coordination steps follow?
• How would a provider from the list versus one outside the list affect tolerance treatment for this file?
• If the estimate is revised, which provider-list and cost documents should I compare?

Questions for a possible provider

• Does this quote cover the exact service and scope the lender requires?
• Which tasks or charges are excluded or could be added later?
• Are you licensed and able to serve this property and transaction?
• Can you meet the lender's delivery, security, and closing requirements?
• How long is the quote valid, and what facts could change it?
• Who will coordinate directly with the lender or settlement team?

The best next step is not to assume that the cheapest-looking line is interchangeable. It is to identify the decision Section C gives you, compare the same work, and confirm that the provider can perform it within the file's requirements.

Official sources used for this article

The statements identified above as official requirements are based on the following federal sources. The checklists and suggested questions are practical education built around those requirements.

1. CFPB: What required mortgage closing services can I shop for?Consumer explanation of Section C, the written provider list, and checking with the lender about an off-list provider. Accessed 2026-08-13.
2. CFPB: Regulation Z § 1026.19 and official interpretationsRules and interpretations for disclosure timing, shopping permission, provider qualifications, the separate written list, and good-faith tolerance treatment. Accessed 2026-08-13.
3. CFPB: Regulation Z § 1026.37 and official interpretationsContent and format of the Loan Estimate, including Section C and examples of possible shoppable services. Accessed 2026-08-13.
4. eCFR: 12 CFR § 1026.38Closing Disclosure content, including the “did shop” and “did not shop” categories. Accessed 2026-08-13.
5. CFPB: Loan Estimate explainerInteractive borrower guide to reviewing the Loan Estimate and its shoppable-services section. Accessed 2026-08-13.
6. eCFR: Appendix H to Part 1026 — Closed-End Model Forms and ClausesOfficial model forms, including the H-27 written list of service providers referenced by the Regulation Z interpretation. Accessed 2026-08-13.