» Key Updates from VA Headquarters: Circular 26-24-19, IECC, and Credit Score Acceptance

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Key Updates from VA Headquarters: Circular 26-24-19, IECC, and Credit Score Acceptance

January 25, 2025

Recent updates from VA Headquarters provide important insights into compliance topics that may impact mortgage brokers and loan originators. While some guidance offers clarity, other areas remain subject to change as the new Administration prioritizes its policies. Below is a breakdown of the key updates.

1.Circular 26-24-19: Invoice Requirements for Itemized Fees and Charges

VA Headquarters addressed several questions regarding Circular 26-24-19, which outlines invoice requirements for itemized fees and charges. One notable issue is the potential acceptance of ALTA statements for title insurance fees. While some lenders have received ServiceNow (“SNOW“) responses indicating that ALTA statements are not acceptable, VA Headquarters expressed a willingness to review this matter. Several examples of ALTA statements have been submitted for evaluation, and further guidance is expected.

It was also clarified that the Circular applies only to fees paid by veterans or assumers and does not apply to fees paid by sellers. Additionally, VA confirmed that appraisal and credit report fees can be collected from veterans at closing, even if these fees have already been paid directly to service providers at the time of service. VA emphasized the importance of ensuring veterans are not “double charged” for these fees.

2.2021 International Energy Code Implementation

VA confirmed its intent to implement the 2021 International Energy Code (“IECC“), but this position is subject to potential changes. The outcome of the lawsuit filed by the National Association of Home Builders (“NAHB“) and 15 state attorneys general against HUD and USDA could influence VA’s stance. Additionally, the Administration’s evolving priorities may also affect the timeline and approach to implementing the IECC, which could have significant implications for energy efficiency standards in new construction.

3.Acceptance of FICO/Vantage Scores

VA shared plans to adopt the use of FICO and Vantage Scores in alignment with other agencies, such as FHFA. However, the timeline for implementation remains uncertain. FHFA has delayed its rollout, originally scheduled for the fourth quarter of 2025, to a date yet to be determined. VA confirmed it intends to move forward with this change when other agencies implement similar updates.

4.Bottom Line

These updates from VA Headquarters provide useful guidance on compliance issues while highlighting areas where changes may occur under the new Administration. We will continue to monitor these developments and provide timely updates.