VA IRRRL – Updated Recoupment and NTB Requirements
In response to continued feedback and clarification from the VA and others, the Carrington Mortgage Services, LLC (CMS) VA Interest Rate Reduction Refinance Loan (VA-IRRRL) Guidelines and Matrix are being republished with updated requirements regarding recoupment and NTB.
As a reminder, The Protecting Veterans From Predatory Lending Act of 2018 (the Act), was enacted to protect Veteran borrowers from predatory lending practices known as “loan churning” or “serial refinancing”, when obtaining a VA-guaranteed refinance loan. CMS has taken steps to ensure all VA-guaranteed loans meet the fee recoupment, net tangible benefit and loan seasoning requirements.
Loan applications submitted on or after May 9, 2019 must meet the following requirements. There will be no impact to the existing pipeline.
When issuing a VA-IRRRL, Lenders must provide the Veteran or borrower with the following fee recoupment and net tangible benefit requirements:
(1) VA IRRRL LTV: Drive-By or Interior Inspection Appraisal required if discount points are charged; Points > 1% Max 90% LTV; Points <= 1% Max 100% LTV; No Points: No appraisal required.