Page 449
Topic 3: FFLR: Purchase/Cash-Out Refinances
Change Date: March 2, 2026
· Topic 3, section a has been updated to specify that lenders use the Loan Review Application Programming Interface (LR API) to provide FFLR files under Circular 26-24-13.
· Topic 3, section b, table 5, item 7, Purchase Agreement has been updated to include the buyer broker representation agreement consistent with Circular 26-24-14.
Page 450
· Topic 3, section b, table 5, item 8 has been updated to include the lender’s provision of invoices under Circular 26-24-19.
· Topic 3, section b, table 5, item 11 has been updated to remove the credit report invoice as the credit report invoice is now included in item 8.
· Topic 3, section b, table 5, item 22, Other Necessary Documents, has been updated to include Verification of Rent or Mortgage and Child Care Statement.
· Topic 3, section b, table 5, items 23 and 24 have been updated to remove the reference to uploading the file.
· The “Alive and Well” statement, included in table 5 item 22 under Other Necessary Documents, has been updated to “Alive and not Missing in Action” statement for consistency with VA Lenders Handbook 26-7 Chapter 9 Topic 8.
a. Background
VA requires lenders to maintain loan origination records and make them available to VA for oversight and audit purposes . When VA selects a loan for FFLR, lenders are to provide the complete loan file to VA within 15 calendar days of VA’s request. A stacking order is provided in section b for FFLR of purchase and cash-out refinance transactions.
17
Lenders submit the loan origination file, Uniform Loan Application Dataset (ULAD) and Uniform Closing Dataset (UCD), and deficiency responses through the LR API. Lenders should refer to VA’s Technology Knowledge Center https://www.benefits.va.gov/HOMELOANS/technology-knowledge-center.asp for LR API, and UCD and ULAD dataset technical specifications.
The loan origination should be a single PDF file. If the file size exceeds VA’s limit, it is permissible to split the file, but it should still follow the stacking order.
The ULAD and UCD are to be provided as separate files in “.xml” format only.
17
38 C.F.R. § 36.4333
b. FFLR Stacking Order: Purchase/Cash-Out
Refinances
Table 5: FFLR Stacking Order: Purchase/Cash-Out Refinances
Order Document
1 Lender’s cover or transmittal letter (if used).
2 If a loan is submitted more than 60 days after loan closing, a statement signed by a corporate officer of the lender which identifies the loan, provides the specific reasons for late reporting, and certifies that the loan is current. This statement must be submitted with any late request for issuance of an LGC . 3 VA Form 26-8937, Verification of VA Benefits (if applicable)
18
Page 451
4 (For Cash-Out Refinances Only) NTB disclosures, evidence that the lender provided the disclosures to the Veteran within three business days of application and at closing
5 Evidence of compliance with NOV requirements, such as, final compliance inspection, termite certification, and/or warranty.
If an escrow of funds is necessary to complete unfinished repairs, provide the escrow holdback agreement or VA Form 26-1849, Escrow Agreement for Postponed Exterior Onsite Improvements. Once the repairs are complete the lender must provide evidence of completion (ex: VA Form 26-1839, Compliance Inspection Report). Refer to Chapter 9 for additional information on Escrows for Postponed Completion of Improvements.
6 URLA
The initial and final application to be provided in the loan file. The final should be fully executed by the borrower(s) at final terms of the loan. 7 (For Purchase Only) Purchase Agreement including all contract addendums, the buyer broker representation agreement, and the signed VA Escape Clause .
19
20
8 Closing Disclosure Statement and invoices for itemized fees under Circular 26-24-19.
9 VA Form 26-8497, Request for Verification of Employment, and/or all other verifications of income such as pay stubs and tax returns. Any income documentation obtained during processing should be provided in the loan file.
10 CAIVRS: borrower/co-borrower
11 All credit reports obtained in connection with the loan and any related documentation, such as explanations for adverse credit if required.
12 VA Form 26-8497a, Request for Verification of Deposit, and/or other related asset documents such as gift letters (Alternative documentation: Original or certified true copies of last two bank statements). Any asset documentation obtained during processing should be provided in the loan file.
13 For Automated Underwriting cases: Feedback Certificate and underwriter’s certification
14 VA Form 26-1820, Report and Certification of Loan Disbursement
15 VA Form 26-6393, Loan Analysis, including any necessary explanations regarding the underwriter’s determination of creditworthiness.
21
16 VA Form 26-0592, Counseling Checklist for Military Homebuyers , if the Veteran is on active duty.
17 All Loan Estimates
Page 452
18 Copies of the fully executed Note and Mortgage/Deed-of-Trust
19 (For Cash-Out Refinances Only) For Cash-Out Refinances only: if the loan being refinanced is a VA loan originated is less than 12 months from the date of closing, a ledger balance or servicing statement to show at least six consecutive payments were made .
22
20 Evidence that any principal reductions were applied to the loan, this includes principal reductions for overcharges or those required to cure. Example: recoupment.
21 (For Cash-Out Refinances Only) For Cash-Out Refinances Only: Evidence of the NTB that was met. For example, NTB is an interest rate reduction, so the most recent mortgage statement or other document to show the current rate should be provided.
22 Other necessary documents (for example – but not limited to, Verification of Rent or Mortgage, Child Care Statement, Adjustable Rate Mortgage/Hybrid Adjustable Rate Mortgage disclosure, Power of Attorney and Alive and not Missing in Action statement if used, Buydown Agreement, Lenders Loan Quality Certification, Escrow Agreement for postponed completion of improvements, Partial Claim Satisfaction)
23
23 ULAD – provided as a separate “.xml” file.
24 UCD – provided as a separate “.xml” file.
18
38 C.F.R. § 36.4303(f)
19
38 C.F.R. § 36.4303(k)(4)
20
12 C.F.R. § 1026.38
21
38 C.F.R. 36.4340(f)(2)(iii)
22
38 C.F.R. §§ 36.4306(b)-(c)
23
Chapter 9 Topic 8