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Topic 4: FFLR: IRRRL
Change Date: March 2, 2026
· Topic 4 section a has been updated to specify that lenders use the LR API to provide FFLR files under Circular 26-24-13.
· Topic 4, section b, table 6, item 3 has been updated to include the lender’s provision of invoices for itemized fees under Circular 26-24-19.
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· Topic 4, section b, table 6, items 20 and 21 have been updated to remove the reference to uploading the file.
· The “Alive and Well” statement, included in table 6 item 19 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 IRRRLs.
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Lenders submit the loan origination file, ULAD and 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.
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38 C.F.R. § 36.4333
b. FFLR Stacking Order: IRRRL
Table 6: FFLR Stacking Order: IRRRLs
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 Closing Disclosure Statement and invoices for itemized fees under Circular 26-24-19.
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4 VA Form 26-8937, Verification of VA Benefits (if applicable)
5 VA Form 26-1820, Report and Certification of Loan Disbursement
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6 The initial and final disclosures reflecting the NTB and recoupment, and evidence that the lender provided the disclosures to the Veteran within three business days of application and at closing.
If applicable, the Veteran’s statement may be combined with the lender’s certification that the Veteran qualifies for the new monthly payment which exceeds the previous payment by 20% or more.
7 VA Form 26-8923, Interest Rate Reduction Refinancing Loan Worksheet
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8 Lender’s Loan Quality Certification , signed by an officer of the company.
9 Lender’s certification that the prior loan was current (not 30 or more days past due) at the time of loan closing. 10 CAIVRS: borrower/co-borrower
11 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. 12 VA Form 26-0592, Counseling Checklist for Military Homebuyers , if the
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Veteran is on active duty.
13 All Loan Estimates
14 Documentation of the cost of energy efficiency improvements included in the loan. For cash reimbursements to the Veteran, the improvements must have been completed within the 90 days immediately preceding the date of the loan.
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15 Evidence the loan meets seasoning for example, a ledger balance to show at least six consecutive payments were made.
16 Copies of the fully executed Note and Mortgage/Deed-of-Trust
17 Evidence that any principal reductions were applied to the loan, this includes principal reductions for overcharges or those required to cure.
Example: recoupment. 18 A copy of the most recent mortgage statement. The statement should be reflective of the current terms of the loan (i.e. interest rate and current payment amount). 19 Other necessary documents (for example – but not limited to, Adjustable Rate Mortgage/Hybrid Adjustable Rate Mortgage disclosure, Power of Attorney and Alive and not Missing in Action statement if used, Buydown Agreement, Partial
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Claim Satisfaction)
20 ULAD – provided as a separate “.xml” file.
21 UCD – provided as a separate “.xml” file.
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38 C.F.R. § 36.4303(f)
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12 C.F.R. § 1026.38
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38 C.F.R. § 36.4340(k)
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38 C.F.R. § 36.4340(f)(2)(iii)
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VA Lenders Handbook Pamphlet 26-7, Chapter 7 Section 3.
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Chapter 9 Topic 8
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