Previously, in connection with the home loan program of the Department of Veterans Affairs (VA) we reported on the VA’s adoption of a temporary local variance allowing veterans to pay the commission of the real estate broker or agent assisting them (a “buyer-broker”). We also reported on a related enhancement made to the Issue Guaranty screen in VA’s WebLGY system.

Originally, the VA advised that the total amount paid by the veteran is to be disclosed in lines 1 through 3 of section H (“Other”) on the Closing Disclosure. We noted that lenders will need to be mindful of the TILA/RESPA Integrated Disclosure (TRID) rule requirement to disclose charges on the Closing Disclosure for which there is no dedicated line in alphabetical order. Apparently, the VA is now aware of the alphabetical order disclosure requirement, as it has revised the guidance by issuing Circular 26-24-14, Change 1 to provide that the amount must be disclosed in section H (“Other”) on the Closing Disclosure, without specifying any particular line for the disclosure.