Compliance News Alert: Nebraska Net Tangible Benefits Disclosure
Jul 28, 2020
On July 24, 2020 the Department of Veterans Affairs amended VA Circ. 26-19-22 for the following reasons:
“A statutory fee recoupment calculation established in Circular 26-19-22 has been successfully implemented by an overwhelming majority of lenders who correctly applied the policy and met the requirements of the Act. However, in a few instances some lenders relied on specific Exhibit B examples in isolation without regard to the guidance provided in the main body of the circular.” (VA Circ. 26-19-22 Chg. 1)
Changes made include clarifications on how energy efficient funds in a refinance Energy Efficient Mortgage, and principal and interest payments for an adjustable-rate mortgage, should be handled in the statutory recoupment calculation. These changes are effective immediately, but loans closed prior to July 24, 2020 with statutory recoupment calculations based on the Exhibit B examples are deemed to be compliant.
We are currently reviewing this announcement to determine any impact, and evaluating any modifications, to our document library and/or systems. Any modifications we make as a result will be announced on our website.
TW 308688
The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third party should consult with an attorney prior to embarking upon any specific course of action.