VA issued Circular 26-24-19, clarifying documentation requirements related to supporting itemized fees and charges to the borrower (or assumer). Per the Circular, reasonable and customary amounts for itemized fees and charges designated by VA may be charged to and paid by the borrower (or assumer). Lenders must now support the amount charged to or paid by the borrower (or assumer) with an invoice or other document that clearly identifies the transaction and verifies the fee and associated charge (an invoice is not required for the VA funding fee). The invoice requirement does not apply to fees included in the lender’s 1% origination fee or fees in the “Seller-Paid” or “Paid by Others” columns on the Closing Disclosure. If the lender is unable to support the charge with an invoice, a refund is to be provided to the borrower (or assumer). The new documentation requirements become effective January 1, 2025.
Click to view the VA Circular 26-24-19: https://www.tenaco.com/wp-content/uploads/2024/09/VA-Circular-26-24-19-09-13-24.pdf
