VA Circular 26-26-1: Updates to VA’s State Fees and Charges Deviations List
Administrative update to VA's approved state fee deviations list for home loan processing
Advisory Assessment
Impact. Your VA loan processing must immediately adopt the updated State Fees and Charges Deviations List, which revises which state-specific fees VA will allow beyond standard charges. This affects fee calculations and loan pricing for all VA loans closed since February 17, 2026, requiring immediate adjustment of your processing workflows and system configurations.
Risk. Operations teams face the highest exposure if they continue using the outdated deviations list, which could result in improper fee assessments that trigger VA compliance findings during routine loan file reviews. The retroactive effective date compounds this risk since any loans processed between February and now using incorrect fee standards are already non-compliant.
Recommended Action. Operations should immediately pull and compare the new deviations list against current processing procedures to identify state-specific changes, then update loan origination systems and retrain processing staff on revised fee allowances. Compliance should audit any VA loans closed since February 17 to confirm proper fee application under the new standards.
Watch. Monitor for any VA guidance clarifying treatment of loans already closed with fees calculated under the previous list, and track whether your state appears on future updates to the deviations list that could affect pricing competitiveness.
Classification
- Regulatory Program
- VA Home Loan Guaranty
- Doc Type
- Guidance
- Effective Date
- 2026-02-17
- Days to Action
- —
- Comment Deadline
- —
- Published
- 2026-02-17
Urgency Basis
Document is effective for loans closed on or after February 17, 2026, and lenders are expected to 'immediately utilize' the new list. Given today's date of May 15, 2026, this is already in effect and requires immediate compliance.
Operational Context
Impact by Category
Key Requirements
Scoring Rationale
This is a routine administrative update to VA's approved fee deviations list. While it requires immediate implementation, the impact is limited to VA loan processing workflows and fee calculations. The change is operational in nature, updating existing procedures rather than creating new regulatory obligations. Scores reflect the need for prompt implementation but recognize the limited scope and incremental nature of the change.