Rules in November 2024 Release
Enterprise

The system has been updated for users submitting VA loans closed on or after January 1, 2025, with enhanced messaging support that aligns with VA Circular 26-24-19. This update introduces new INFO status messages on VA invoice requirements for itemized fees and includes changes to the State Fees & Charges Deviations List. New INFO status messages provide guidance on processing itemized fee charges and any applicable state fee deviations.
VA State Fees and Charges
Invoices for Itemized Fees and Charges
Other than the VA Funding Fee, lenders must support the amount charged to the Veteran with an invoice or other document that clearly identifies the transaction and verifies the fee and associated charge. In (State Abbr.), Lenders may not charge the Veteran more than the actual amount charged for the fee or service performed and may not charge the Veteran for services paid for by another party. The invoice requirement does not apply to fees included in the lender's 1%. The invoice requirement does not apply to fees in the "Seller-Paid" or "Paid by Others" columns on the Closing Disclosure. (VA Circular 26-24-19; 38 USC 3729; 38 CFR 36.4313)
VA State Fees and Charges Deviations List
(State Abbr.) is a state with fees on the VA State Fees and Charges Deviations List. The Veteran may pay reasonable and customary amounts for fees and charges, provided they are supported by an invoice. Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. The invoice requirement does not apply to fees included in the lender's 1% or to the VA Funding Fee. The invoice requirement does not apply to fees in the "Seller-Paid" or "Paid by Others" columns on the Closing Disclosure. VA recognizes certain government mandated fees do not have an invoice. These fees, specifically identified on the State Fees and Charges Deviations List, do not require an invoice, but the lender may not charge more than the amount listed. (VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)
Federal - VA Loan Origination and Other Restricted Fees - State Fee Deviation
Verification Fee Excluded from VA 1% (State Fee Deviation Sheet)(1001280)
This loan contains a Verification Fee of ($_) paid by a borrower. Under VA Guidelines for (State Abbr.), a veteran can exclude a charge for a Verification Fee from the "unallowable fees". Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. (38 CFR 36.4313; VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)
Closing Protection Letter Excluded from VA 1% (State Fee Deviation Sheet)(1001280)
This loan contains a Closing Protection Letter Fee of ($_)paid by a borrower. Under VA Guidelines for (State Abbr.), a veteran can exclude a charge for a Closing Protection Letter Fee from the "unallowable fees". Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. (38 CFR 36.4313; VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)
Municipal Lien Fee Excluded from VA 1% (State Fee Deviation Sheet)(1001280)
This loan contains a Municipal Lien Fee of ($_) paid by a borrower. Under VA Guidelines for (State Abbr.), a veteran can exclude a charge for a Municipal Lien Fee from the "unallowable fees". Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. (38 CFR 36.4313; VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)
Title Endorsement Fee Excluded from VA 1% (State Fee Deviation Sheet)(NY)(1001280)
This loan contains a Title Endorsement Fee of ($_) paid by a borrower. Under VA Guidelines for (State Abbr.), a veteran can exclude a charge for a Title Endorsement Fee from the "unallowable fees". Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. (38 CFR 36.4313; VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)
Federal - VA Loan Origination and Other Restricted Fees - Fee Deviation (Illinois)
Settlement/Closing Fee Excluded from VA 1% (State Fee Deviation Sheet)(IL)(1001400)
This loan contains a Settlement or Closing Fee of ($_) paid by a borrower. Under VA Guidelines for Illinois, a veteran can exclude a charge for a Settlement or Closing Fee from the "unallowable fees". Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. (38 CFR 36.4313; VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)
Settlement/Closing Fee Excluded from VA 1% (State Fee Deviation Sheet)(IL)(1001400)
This loan contains a Settlement or Closing Fee of ($_) paid by a borrower. Under VA Guidelines for Illinois, a veteran can exclude a charge for a Settlement or Closing Fee from the "unallowable fees". Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. (38 CFR 36.4313; VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)
Refer to the VA Circular for details on itemized fees and charges. For additional questions, contact the VA through their Service Portal or by calling 1-877-827-3702.
CER-24161
State Rules

You can now submit your Iowa loans to
Rule Headers:
- Iowa - Usury Rate (Regulated)(1000518)
- Iowa - Fees Not Allowed (Industrial Loan)(52600)
The system will apply the updated Iowa rules to loans below the new threshold, reflecting the Iowa Consumer Credit Code (Act 1660). This change is based on adjustments to the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), effective as of June 1, 2024.
For detailed information on the TILA threshold adjustments, please visit the Consumer Financial Protection Bureau's announcement.
CER-23928

CER-24130

The system has been updated for users submitting New York loans subject to Subprime Threshold testing to be evaluated using the TIL/Reg Z APR rounded to three decimal places, aligning with the New York Subprime thresholds under, including:
Rule Headers:
- New York - Subprime Home Loan (First Lien)(02/10)
- New York - Subprime Home Loan (Junior Lien)(02/10)
CER-24212

The system has been updated so that users submitting Texas loans will now receive a FAIL status message under the Texas Credit Title - Interest Provisions for loans secured by a primary dwelling with a prepayment penalty and an APR greater than 12%, aligning with Tex. Fin. Code 302.102. Previously, the system applied this prepayment penalty restriction regardless of occupancy type.
Texas - Prepayment Penalty Not Allowed (APR > 12%)
Prepayment Penalty Not Allowed (APR > 12%)(9220)
The (_%) APR does not exceed 12%. The Texas Credit Title Interest Provisions prohibit a prepayment penalty on a loan with an interest rate greater than 12%. (Tex. Fin. Code 302.102)
Prepayment Penalty Not Allowed (APR > 12%)(9220)
The (_%) APR exceeds 12%. The Texas Credit Title Interest Provisions prohibit a prepayment penalty on a loan with an interest rate greater than 12%. (Tex. Fin. Code 302.102)
CER-24292