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 [2019]).
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/).