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VA Amends Interest Rate Reduction Refinance Loan (IRRRL) Requirements in Light of Economic Growth, Regulatory Relief and Consumer Protection Act of 2018

VA issued Circular 26-18-13 (Circular), setting forth amended Interest Rate Reduction Refinance Loan (IRRRL) requirements in light of the recently passed Economic Growth, Regulatory Relief and Consumer Protection Act of 2018. Per the Circular, the lender (including any broker, servicer or issuer of an IRRRL) must provide a net tangible benefit test to a borrower in connection with an IRRRL. The Circular also announces a revised seasoning period for loans refinanced as an IRRRL. An IRRRL may not take place until at least 210 days after the date on which the first payment is made, or the date on which the sixth monthly payment is made, whichever occurs later. In addition, the lender (including any broker, servicer or issuer of an IRRRL), must provide recoupment statements to VA in accordance with Circular 26-18-1 and 26-18-1 Change 1 (Policy Guidance for IRRRLs), and certify that all fees and incurred costs will be recouped within 36 months of the date of the loan. The amended IRRRL requirements went into effect May 25, 2018.

Click Here to View the VA Circular 26-18-13

Click Here to View the VA Circular 26-18-13, Exhibit A

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