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T4 VA Low Confidence Guidance

VA Circular 26-26-1: Updates to VA’s State Fees and Charges Deviations List

Administrative update to VA Home Loan Guaranty fee deviation reference list

MINIMAL
Impact Level
Top: Compliance (1)

Advisory Assessment

Impact. This circular updates the VA's reference list for state-specific fee deviations that lenders can charge on VA-guaranteed loans, requiring institutions to refresh their internal fee calculation matrices and pricing systems. The changes affect how you structure closing costs and third-party fees for VA borrowers in states with approved deviations.

Risk. Fee calculation errors represent the primary exposure, particularly in states where deviation parameters have shifted since your last system update. Loan officers and operations staff working from outdated fee schedules could inadvertently overcharge VA borrowers or price loans incorrectly, creating potential examination findings during routine VA compliance reviews.

Recommended Action. Pull the updated deviation list from VA's website and cross-reference it against your current VA loan pricing matrices within the next two weeks. Have operations leadership validate that loan origination systems reflect any changes to allowable state fees before processing additional VA applications in affected states.

Watch. Monitor VA's quarterly updates to this deviation list, as fee structures can shift with state regulatory changes. Track any borrower complaints about unexpected closing costs in states with recent deviation adjustments, as these could signal system configuration issues requiring immediate correction.

Classification

Regulatory Program
VA Home Loan Guaranty
Doc Type
Guidance
Effective Date
Date not stated
Days to Action
Comment Deadline
Published
2026-02-17

Urgency Basis

Administrative update to fee deviation list with no specified compliance deadline or material obligations

Operational Context

Affected Functions
Compliance Operations
Institution Applicability
All

Impact by Category

Compliance
1
Operational
1
Data Governance
0
Model Risk
0
Reporting & Disclosure
0
Capital & Liquidity
0
Consumer Protection
0
Third-Party Risk
0

Key Requirements

- Review updated VA State Fees and Charges Deviations List - Update internal VA loan fee calculation references - Ensure compliance with revised state fee deviation parameters

Scoring Rationale

This is a routine administrative circular updating the VA's State Fees and Charges Deviations List. The document provides minimal detail but appears to be a technical update to existing fee structures rather than substantive policy change. Given the administrative nature and lack of specific compliance deadlines, this scores minimal across operational categories with T4 urgency for monitoring purposes.

Scored: 2026-05-15T23:39:24.228Z Model: claude-sonnet-4-20250514 Confidence: Low Aggregate Score: 1.0
AI Analysis Disclosure — This record, including its scores, impact assessments, and Advisory Assessment (impact, risk, and recommended actions), was generated by an AI model and may contain errors or omissions. The Advisory Assessment is a starting point for analysis, not a substitute for professional judgment. Effective dates, applicability determinations, impact assessments, and any recommended actions should be independently verified against primary regulatory source documents and reviewed by qualified compliance or legal personnel before taking compliance action. This output does not constitute legal or compliance advice.