On August 8, 2019 the VA published VA Circ. 26-19-22 (available at: https://www.benefits.va.gov/HOMELOANS/resources_circulars.asp) which provides preliminary guidance from the VA and the correlation between Interest Rate Reduction Refinance Loans (“IRRRL”) and the “Economic Growth, Regulatory Reform, and Consumer Protection Act” (113 Stat. 1038 ).
Notable parts of the Circular include clarification on whether an adjustable-rate mortgage can be refinanced by a fixed-rate IRRRL with a higher interest rate (it can), whether the principal and interest payment of the IRRRL can increase over that of the loan being refinanced (it can), and a new, sample comparison statement which can be used to determine whether the IRRRL recoups fees.
We are currently reviewing this change to determine any impact to our document library and/or systems and evaluating any necessary changes. Any modifications we make will be announced on our website (https://compliance.docutech.com/).