In the March 7, 2024 issue of the Federal Register (89 FR 16491, click here), the Department of Veterans Affairs issued a supplemental notice of proposed rulemaking to revise a November 1, 2022 proposed rule to amend its regulations on VA-backed interest rate reduction refinancing loans (November 2022 proposed rule can be found at 87 FR 65700, click here). The November 2022 proposed rule (Proposed 38 CFR Part 36.4307(a)(8)) would create a recoupment formula for fees, closing costs, and expenses to be recouped within thirty-six months of a loan’s “issue date”. The original proposed rule was to measure the “issue date” from the Note date. The revision to the proposed rule will instead measure the “issue date” and the thirty-six-month recoupment period from the date of first payment.


Full Memorandum