BLOG

FAQ – VA and Itemized Fees 

Question: Has the Department of Veterans Affairs (VA) taken any action in furtherance of its requirement for lenders to support amounts charged to a VA borrower with an invoice as highlighted in Circular 26-24-19, which was effective on January 1, 2025.

 Answer:

Yes.   As detailed in our prior FAQ, on September 13, 2024, the VA published Circular 26-24-19: Invoice Requirements for Itemized Fees and Charges and Updates to the State Fees & Charges Deviations List, The Circular clarifies when a lender needs to provide an invoice to support itemized fees charged to, or paid by, the borrower for VA loan transactions.  

Recently, the VA has begun to issue deficiency letters to lenders citing to missing invoices for items such as title insurance, title searches, recording fees, and closing protection letters (CPLs).  These deficiency letters specifically state that a Closing Disclosure is not acceptable and that an invoice must be provided.  The letter allows the lender 30 days to correct the deficiency and threatens administrative sanctions and indemnification if the invoices are not timely received.

Lenders are reminded that they must obtain an invoice from the tile company prior to closing that accurately lists the title fees set forth on the Closing Disclosure.