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Refinancing and HELOCs

FHA Streamline vs. VA IRRRL: Which Refinance Rules Apply?

Both let you refinance with less paperwork, often with no appraisal and no income check. But who qualifies, what it costs and the benefit test are different. Here's a side by side look.

By Dane Foxworthy, NMLS #2577438

They're both "streamlined," but they aren't the same program

An FHA Streamline refinances an existing FHA insured mortgage. A VA Interest Rate Reduction Refinance Loan, or IRRRL, refinances an existing VA guaranteed loan.

Neither program should be described as "no qualification" or "no rules." Streamlined refers to reduced documentation or underwriting compared with a standard refinance. Each program still has eligibility, seasoning and benefit requirements.

FHA Streamline: the core rules

HUD states that the mortgage being refinanced must already be FHA insured, the mortgage must be current, and the transaction must create a net tangible benefit for you.

FHA permits credit qualifying and non credit qualifying streamline options. The distinction affects documentation and underwriting.

HUD also limits cash back on a streamline. Cash in excess of $500 may not be taken out through the streamline process.

A streamline doesn't mean there are no closing costs. HUD specifically warns against that misunderstanding.

FHA seasoning isn't optional

Current FHA handbook policy requires the existing FHA loan to satisfy seasoning before a streamline case number can be assigned. The standard has historically required at least six payments, six full months after the first payment due date and at least 210 days from the prior loan's disbursement date.

Because FHA handbook updates can change details, the lender should verify the effective version of Handbook 4000.1 for the new case number.

The FHA net tangible benefit test can be more technical than "lower rate"

FHA compares the old and new combined rate, which includes the mortgage interest rate plus the annual MIP rate, and applies specific standards depending on whether you are moving between fixed and adjustable rate structures and whether the term is reduced.

That means a nominal note rate reduction doesn't by itself prove the refinance qualifies.

The lender should be able to show the actual FHA net tangible benefit calculation, not just tell you the new rate is lower.

VA IRRRL: the core rules

VA describes an IRRRL as a VA to VA refinance. You must already have a VA loan on the property.

VA states that an appraisal or full credit underwriting package is generally not required for an IRRRL. A private lender can still impose its own overlays or documentation requirements.

You may not receive cash from an IRRRL. A second mortgage generally can't be paid off with IRRRL proceeds; the second lien holder must agree to subordinate if the lien will remain.

VA has specific anti churning requirements

VA IRRRLs are subject to federal seasoning, recoupment and net tangible benefit rules.

VA guidance explains that the existing loan is seasoned when you have made at least six consecutive monthly payments and the new refinance closes at least 210 days after the first payment due date of the old loan.

VA recoupment rules generally require applicable refinance costs to be recovered through payment savings within 36 months, with exclusions and special rules defined by VA. The new loan must also satisfy VA's net tangible benefit requirements.

These rules were designed to prevent repeated refinances that generate fees without enough financial benefit to the Veteran.

The VA funding fee is part of the comparison

VA currently lists the IRRRL funding fee at 0.5% unless you are exempt from the funding fee.

The fee can often be financed, but financing it increases the new loan balance. A lower monthly payment should therefore be compared with the increase in principal, not evaluated in isolation.

FHA and VA treat occupancy differently

For an FHA Streamline, HUD permits certain formerly owner occupied properties to be refinanced under streamline rules subject to program restrictions, including appraisal limitations for investment properties.

For a VA IRRRL, VA uses a different occupancy standard from a purchase loan: the Veteran generally certifies prior occupancy rather than current occupancy.

These are program specific exceptions. Don't apply them to a standard FHA cash out refinance or VA cash out refinance.

Example: the lower rate that still needs to pass a benefit test

Assume you can reduce a rate by 0.50 percentage points but must finance several thousand dollars of allowable costs.

For an FHA Streamline, the lender still has to demonstrate the FHA defined net tangible benefit, including the effect of MIP and term.

For a VA IRRRL, the lender must evaluate VA's rate/payment benefit and recoupment requirements.

The phrase "half point lower" doesn't answer either program's full test.

What to request from the lender

For FHA, ask for:

  • the current and new combined rate,
  • the net tangible benefit calculation,
  • the treatment of closing costs and UFMIP,
  • whether the transaction is credit qualifying or non credit qualifying,
  • and the old versus new total payment.

For VA, ask for:

  • the old versus new loan comparison,
  • the recoupment calculation,
  • the seasoning dates,
  • the funding fee or exemption status,
  • and confirmation that the transaction meets VA's net tangible benefit standard.

Bottom line

FHA Streamlines and VA IRRRLs can be excellent refinance tools because they may require less documentation than a standard refinance. Their value comes from correctly using the program, not from pretending the rules disappeared.

If a lender can't explain the benefit test, seasoning and financed costs in plain English, keep asking questions before signing.

Common questions

Does a VA IRRRL need an appraisal?

Usually not. Most IRRRLs close without an appraisal or income check, though some lenders add their own requirements.

Can I do an FHA streamline if I'm behind on payments?

Generally no. FHA wants a recent record of on time payments and a minimum amount of time on your current loan.

Do both refinances have to lower my payment?

Each has a benefit test. FHA requires a net tangible benefit, like a lower combined rate and insurance cost. A VA IRRRL usually must lower your rate, except when moving from an adjustable rate to a fixed rate, and the costs must be recouped within 36 months.

Talk it through with Dane.

You do not need to be ready to apply. Send the property, the question or the plan, and I will tell you what I see.