What changed

VA issued a Home Loan Policy Circular updating the VA State Fees and Charges Deviations List. The circular directs lenders to use the new list immediately.

That makes this more than a policy-awareness item. For VA pipelines, a stale deviations list can flow directly into fee setup, invoice support, closing-cost review, and file evidence. The near-term task is to confirm that active and upcoming VA files are being reviewed against the current list, not a prior internal copy.

The operational hinge

The hinge is state-specific fee treatment. If a lender’s internal fee matrix, closing review checklist, or processor instruction still reflects the prior deviations list, teams may approve or document a fee position using outdated support.

The circular excerpt provided does not identify the specific state-by-state changes. That means the safest operational response is not to summarize the changes from memory. It is to verify the current VA list directly against the lender’s own fee tables and file-review workflow.

Immediate review gates for VA loan teams

1. Confirm the current source of truth

Identify where the VA State Fees and Charges Deviations List is stored or referenced internally. That may include fee matrices, policy job aids, processor instructions, closing checklists, QC scripts, and any state-specific exception references used before closing.

For each location, document whether the new VA list has replaced the prior version and who approved the update.

2. Recheck files approaching closing

For VA loans that have not yet closed, closing and compliance teams should verify that state-specific fee treatment has been checked against the new list. The review should be especially explicit where the file relies on a state deviation or exception handling.

If a file’s fee treatment was reviewed before the update, route it through the lender’s existing correction or escalation process rather than assuming the prior review remains current.

3. Tie invoice support to the current list

Where the file includes invoice support for fees affected by state-specific handling, make sure the support is connected to the current list review. The practical audit question is simple: can a reviewer see what list was used, when it was checked, and how the fee position was supported?

If the answer is no, the file may need a clearer note, checklist entry, or retained evidence under the lender’s documentation standards.

4. Check closing disclosure workflow dependencies

The recommendation flags closing disclosures as a review point. Teams should confirm that the closing-cost workflow is using the updated list before final review, not merely that the policy department has received the circular.

A useful control is to add a short verification step for VA files in affected state-specific workflows: current VA deviations list checked, fee treatment confirmed, support retained, and reviewer identified.

5. Assign ownership for state-by-state validation

Do not leave the update as a general announcement. Assign a specific owner to compare the new VA list against internal state-by-state fee guidance and to confirm completion with closing, processing, compliance, and QC stakeholders.

The owner should also decide where the evidence of the update lives: policy log, fee-matrix change record, file checklist, QC worksheet, or another controlled location already used by the lender.

Documentation questions to ask now

  • Which internal fee matrices or state-specific guidance reference the VA deviations list?
  • Has each reference been updated to the new list?
  • Who validated the update, and when?
  • Are open VA files being reviewed under the new list before closing?
  • Where does the file show the list version or review date used for fee approval?
  • Does invoice support align with the current fee treatment?
  • Do closing and QC teams have the same instruction, or are they operating from different copies?

Caveat for reviewers

This note is based on the VA circular signal and supplied source metadata, including the title and excerpt. The provided material confirms that the list was updated and that lenders are directed to use the new list immediately, but it does not provide a substantive state-by-state change summary. Teams should review the VA circular and list directly before making file-specific determinations.