Rate Lock Agreement vs. Change of Circumstance: What’s the Real Difference for Homebuyers?

During the mortgage process, you may receive both a Rate Lock Agreement and, at some point, a Change of Circumstance notice from your lender.

At first glance, both seem to indicate something has changed with your loan — but they serve very different purposes.

A Rate Lock Agreement is a formal contract that guarantees your interest rate and loan pricing for a set period of time. A Change of Circumstance (CoC) is a compliance-regulated event that allows your lender to update your Loan Estimate (LE) or Closing Disclosure (CD) when verified information about your loan changes.

Understanding how these two differ helps you recognize what’s part of your normal loan process — and what signals a regulatory update that may impact your costs or disclosures.

Key Takeaways

Rate Lock Agreement:

A formal contract that guarantees your interest rate and pricing for a set period — typically 30, 45, or 60 days.

Change of Circumstance (CoC):

A regulated event that allows your lender to reissue your Loan Estimate or Closing Disclosure when verified loan details change.

Biggest Difference:

Rate Lock Agreement = rate protection.

Change of Circumstance = disclosure update.

💡 Pro Tip: Anytime your lender reissues a Loan Estimate after locking your rate, ask what triggered the Change of Circumstance — then upload your updated Loan Estimate to Fincast to confirm your deal is still competitive (no extra credit pulls, no spam).

What Is a Rate Lock Agreement?

A Rate Lock Agreement (sometimes called a “Rate Lock Confirmation”) is a formal, written agreement between you and your lender that guarantees your interest rate and pricing for a specified time — usually 30, 45, or 60 days.

It protects you from market rate increases while your loan is in process and underwriting.

A Rate Lock Agreement typically includes:

• Locked interest rate and loan program

• Lock period and expiration date

• Applicable points, credits, or pricing adjustments

• Rate lock terms and extension policy

• Borrower and property details

👉 Think of a Rate Lock Agreement as your rate guarantee — it ensures your pricing won’t change while your loan is being finalized (as long as you close within the lock period).

What Is a Change of Circumstance?

A Change of Circumstance (CoC) is a formal, compliance-triggered event that allows your lender to reissue or update your Loan Estimate (LE) or Closing Disclosure (CD) when verified information about your loan changes.

Under TRID (TILA-RESPA Integrated Disclosure) rules, lenders can only adjust fees or reissue disclosures if a valid CoC has occurred.

Common examples include:

• Loan amount or program change

• Property value or appraisal update

• Borrower income, assets, or credit changes

• Rate lock or lock extension (yes — locking your rate can trigger a CoC)

• Revised title or third-party fees

👉 Think of a Change of Circumstance as your loan’s official update — it documents and justifies any changes to your loan costs or terms.

Rate Lock Agreement vs Change of Circumstance: Side-by-Side

How Should I Use Both When Buying a Home?

Each plays an important role — one locks in your rate, the other ensures regulatory compliance when your loan terms change.

Step 1: Lock Your Rate

Once your application is complete and you’re satisfied with your terms, lock your rate. You’ll receive a Rate Lock Agreement confirming your guaranteed rate, pricing, and expiration date.

Step 2: Watch for Updates

If your lender reissues your Loan Estimate or Closing Disclosure after you lock, there’s likely been a Change of Circumstance.

Step 3: Review the Changes Carefully

Compare your new disclosures to the old ones — confirm what changed, why, and whether those changes were triggered by your rate lock or another verified factor.

Step 4: Ask for Clarification

Your lender is required to document every CoC in writing — don’t hesitate to ask for the reason behind any adjustments.

Step 5: Upload to Fincast

Upload your updated Loan Estimate to Fincast. The platform benchmarks your deal against vetted lenders, ensuring that your updated terms remain competitive.

Why Both Matter

Your Rate Lock Agreement protects your rate.

Your Change of Circumstance explains any updates to your costs or disclosures.

Together, they create transparency — protecting your loan terms while keeping your lender accountable for every change.

Compare Real Offers Effortlessly Using Fincast

Before moving forward with a new disclosure or extended lock, take a moment to verify your deal.

Upload your Loan Estimate to Fincast to confirm whether you have a competitive deal or if there is a better offer available.

✅ No multiple applications

✅ No extra credit pulls

✅ No spam

You’ll see exactly how your deal stacks up — before you close.

FAQs

1. Is a Rate Lock Agreement the same as a Change of Circumstance?

No. A Rate Lock Agreement guarantees your rate; a Change of Circumstance triggers verified updates to your loan.

2. Can a rate lock trigger a Change of Circumstance?

Yes — locking or extending a rate often triggers a CoC, since it can change loan pricing or fees.

3. Do I get new disclosures after a CoC?

Yes. Your lender must reissue your Loan Estimate or Closing Disclosure when a valid CoC occurs.

4. Can my rate change after locking?

Not during the lock period, unless your loan details change—which could trigger a new CoC.

5. How does Fincast help?

Fincast benchmarks your Loan Estimate across vetted lenders — confirming your updated deal is fair, compliant, and competitive.

Bottom Line

Rate Lock Agreement = rate guarantee.

Change of Circumstance = disclosure update.

One protects your pricing; the other documents your changes.

With Fincast, you can confirm your locked rate — and any new costs — are accurate, justified, and working in your favor.

Pro Tips (Save These!)

✅ Lock your rate only when you’re ready to move forward.

✅ Track your lock expiration date closely.

✅ Ask your lender to explain any Change of Circumstance notices.

✅ Always compare new disclosures line by line.

✅ Upload your updated Loan Estimate to Fincast to verify your deal.

Action Checklist

☑️ Lock your rate and review your Rate Lock Agreement

☑️ Watch for Change of Circumstance notices

☑️ Compare updated disclosures carefully

☑️ Ask your lender to explain all changes

☑️ Upload your Loan Estimate to Fincast for instant benchmarking

👉 Ready to verify your rate and costs?

Upload your Loan Estimate to Fincast and confirm that your loan and pricing are competitive with the current market.