VA Cash-Out Refinance (non-IRRRL) loans submitted to the System with an Application Date on or after February 15, 2019, will receive Mavent Message(2290020) ERROR when running the VA Enterprise Rules Reviewer and Purpose of Loan (field ID 19) is set to Cash-Out Refi or No Cash-Out Refi.
RESOLUTION
To alleviate the ERROR, the following values need to be complete from the prior loan being refinanced:
□ Existing Lien (field ID 26)
□ Existing Loan Date (field ID NTB.X1)
□ Loan Amount (field ID NTB.X2)
□ Loan Term (field ID NTB.X3)
□ Months Remaining (field ID NTB.X4)
□ Amortization Type (field ID NTB.X5)
BACKGROUND
As a result of VA Circular 26-18-13, VA-guaranteed loans must be meet the new seasoning requirements before being refinanced. The required seasoning period is the later of; (a) The date that is 210 days after the date on which the first payment is made on the loan, and; (b) The date on which the sixth monthly payment is made on the loan. The seasoning period applies when refinancing to an IRRRL, also known as a VA streamline refinance. The seasoning period also applies to cash-out refinances when the principal amount of the new loan is less than the loan being refinanced. (Seasoning shall not apply to a VA cash-out or “regular” refinance if the principal amount of the new cash-out loan will exceed the amount of the loan being refinanced.) These requirements affect loan applications taken on or after May 25, 2018.
VA Circular 26-18-13: Policy Guidance Update: VA Refinance Loans and the Economic Growth, Regulatory Relief and Consumer Protection Act