VA is only asking the lender to take the information they already collect from and provide to veterans, and display and provide that information into an easy to read format for the veteran
- Summary of collection of information: The new collection of information in 38 CFR (a)(3) requires lenders to provide borrowers with a net tangible benefit test. To satisfy the net tangible benefit test, the new loan must meet certain loan criteria; the lender must provide a comparison of the terms of the borrower’s current loan to the terms of the new loan; and the lender must provide the borrower a statement concerning the effects of refinancing on the borrower’s home equity. This information must be provided to the borrower by the lender in a standardized format not later than 3 business days of the refinance application and again at closing. The borrower must acknowledge receipt of this information on both occasions by signing the certification.
VA notes that it will not require lenders to complete a specific form. VA created a sample certification as an example, but this is not a required document or format.
- Description of need for information and proposed use of information: The information will be used by VA to ensure that the new loan meets the net tangible benefit test.
- Description of likely respondents: Lenders refinancing an existing loan product through a cash-out refinance loan.
- Estimated number of respondents: VA anticipates the annual estimated number of respondents to be 156,000 per year, which is based on a 3-year average of VA cash-out refinance loans. VA also estimates a one-time burden to the 16,000 loan officers who will require training on the new disclosure requirements. Continue reading