VA Fee and Invoice Rules in 2026: What You Can Charge a Veteran

The VA loan fees invoice rules for 2026 have undergone significant changes, particularly with the release of VA Circular 26-24-19 Change 1. Mortgage brokers must stay informed about these updates to avoid compliance issues and ensure smooth processing of VA-guaranteed loans. This post will explore the new rules, especially concerning invoice submissions and itemized fees, and provide actionable insights for brokers.

What changes have been made to VA loan fees invoice rules in 2026?

The most notable change in the 2026 VA loan fees invoice rules is the adjustment in how invoices are handled for itemized fees and charges. According to VA Circular 26-24-19 Change 1, lenders are no longer required to submit invoices at the time of Full File Loan Review (FFLR), manual guaranty requests, or assumptions. Instead, lenders must maintain supporting documentation in their loan files and provide it to the VA upon request, including during audits by the VA Monitoring Unit.

This change simplifies the process for lenders, reducing the immediate paperwork burden at the time of loan submission. However, it also places a greater responsibility on brokers to ensure that all documentation is meticulously maintained and readily accessible for potential audits.

What are the requirements for maintaining invoices and supporting documents?

Under the new rules, lenders must retain invoices from service providers in their loan files. These documents must be available for VA requests and oversight activities. The VA Circular 26-24-19 Change 1 specifies that invoices should clearly identify the transaction and verify the fee and associated charge. This includes any itemized fees and charges that are charged to or paid by the Veteran.

Here are the key takeaways for maintaining compliance:

• Retain all invoices: Keep invoices for itemized fees and charges in the loan file.
• Ensure clarity: The invoices must clearly identify the transaction and verify the fee.
• Be audit-ready: Have documentation accessible for VA audits and requests.

How do these changes impact the handling of itemized fees and charges?

The handling of itemized fees and charges remains a critical aspect of VA loan processing. According to VA Circular 26-24-19, lenders can charge Veterans reasonable and customary amounts for itemized fees as designated by the VA, provided these fees are incidental to the loan. The VA Lenders Handbook, Pamphlet 26-7, outlines these fees, which include:

• VA funding fee (unless exempt)
• VA appraisal and repair inspections
• Credit report fees
• Recording fees and taxes
• Prepaid items, applicable taxes, hazard insurance, flood insurance, and assessments
• Title examination and insurance fees
• Mortgage Electronic Registration Service (MERS) fee
• Flood determination and survey fees

Lenders must ensure that these fees are supported by an invoice or other documentation that verifies the fee and associated charge. Importantly, the invoice requirement does not apply to the VA funding fee or fees included in the lender’s one percent fee.

What should brokers do to comply with the new VA loan fees invoice rules?

To comply with the new VA loan fees invoice rules, brokers should implement the following practices:

1. Review and update processes: Ensure that your processes for maintaining and retrieving invoices align with the new requirements. This may involve updating your document management systems or training staff on the new procedures.

2. Conduct regular audits: Periodically review loan files to ensure all required documentation is present and correctly filed. This proactive approach can help identify and rectify issues before a VA audit.

3. Educate your team: Make sure that your team is aware of the changes and understands the importance of maintaining accurate and complete documentation.

4. Stay informed: Keep up to date with any further changes to VA guidelines and circulars. Regularly check the VA’s official communications for updates.

By adhering to these practices, brokers can ensure they remain compliant with the VA’s requirements and avoid potential issues during audits.

For more operational guidance, see the Mortgage Broker Operations hub.

This article is for informational purposes only and is not professional advice. Always verify against current guidelines before making decisions.