Everything traces to the record
Evidence & oversight
Every claim below carries a content label, a primary source, a plain-language definition, its limitation, and the date it was last verified. Filter by label or search the text. Full source register: data & methods.
On this page ↓ Quotes on the record · Family voices · For Reporters
The rebuttal library
The Rebuttal Index, what families keep hearing, and what the record says
Twenty-two fact-led rebuttals of the lines the VA and servicers recycle, with seven more in preparation, each with rule text and a citation. Pattern-level, no names.
Read the Rebuttal Index →Quotes & family voices
② Why it matters · On the record
Words on the record, in a family’s own voice, and where they were said. The full, filterable claim library, every stat with its source, label, and date, is below. Definitions live in Data & Methods; press contact and ground rules are on For Reporters.
Quotes on the record, with citations
“Foreclosure. Period.”
Mortgage Bankers Association (Elizabeth Balce) on the consequence of ending VASP, March 2025, establishes foreseeability. Source ↗
The VA must pause foreclosures until the new assistance program is actually accessible.
National Consumer Law Center, June 15, 2026. Read the statement ↗
Twenty-eight members of the House demanded the VA establish a targeted foreclosure moratorium.
Rep. Chris Pappas + 27 colleagues, May 26, 2026. Read the letter ↗
② Why it matters · On the record
FAMILY’S OWN PUBLIC MATERIALSMaterials a cohort family has published themselves or given on camera. We link the original, don’t restate case details, and no minor is named or shown.
On camera
Leann Ledford, project lead, on the MS NOW Weekend Primetime panel, the crisis in a family’s own voice.
Watch the clip →In writing
A self-published essay: “We were not allowed to pay our mortgage.” The forbearance-to-foreclosure arc, first-hand.
Read the essay →The public fundraiser
A cohort family’s own GoFundMe, the household-level stakes behind the cohort numbers.
See the page →Published at the family’s choice; no case numbers, no minor named or shown, full firewall policy →
Working on a story?
Press desk → For Reporters
Contact and response expectations, downloads (One-Pager, First 72 Hours, cleaned CSVs), the source bundle and interview requests, interview protocol and ground rules, and background reading, all on one page.
Go to For Reporters →The claims register · 58 claims · rendered from data/claims.csv
Every number on this site resolves to a row here. Use your browser’s find (Ctrl-F / Cmd-F) to search. Download the register (CSV).
DOCUMENTED FACT C001
At least 15,000 veteran families have already been foreclosed on or displaced.
Figure stated by Sen. Blumenthal at SVAC 5/20/26
Limitation: Spring 2026 count; no newer figure published; true number likely higher (stale-stats rule)
S001 · Sen. Blumenthal remarks, SVAC hearing (15,000+ figure) ↗
Last verified 2026-07-15
DOCUMENTED FACT C002
More than 90,000 veteran homeowners are behind on their loans or in the foreclosure process.
NPR/ICE data 4/2/26; NCLC put ~31,500 in active foreclosure
Limitation: Spring 2026; stale-stats rule applies
S002 · NPR VA foreclosure investigation (Arnold/Lawrence) ↗
Last verified 2026-07-15
DOCUMENTED FACT C003
About 160,000 veteran families are impacted in total.
Foreclosed + in the pipeline + forced into unaffordable modifications or short sales
Limitation: Campaign-compiled sum of the three tiers; not an official single figure; never merge into one number
S001 · Sen. Blumenthal remarks, SVAC hearing (15,000+ figure) ↗S002 · NPR VA foreclosure investigation (Arnold/Lawrence) ↗
Last verified 2026-07-15
DOCUMENTED FACT C004
The permanent partial claim was scored as net savings; foreclosure is the more expensive option.
$147 million in net savings over ten years (CBO; H. Rept. 119-104)
Limitation: CBO estimate over the ten-year scoring window
S005 · CBO score, H. Rept. 119-104 Sec. 3 ↗
Last verified 2026-07-22
DOCUMENTED FACT C005
The average VA foreclosure loss is roughly $72,000 to $74,000.
NCLC ~$72,000; CRL ~$74,000 (~$73,750 per disposition)
Limitation: Cite whichever figure with its own source label; do not blend
S003 · NCLC analysis to HVAC EO Subcommittee (Cohen) ↗S004 · Foreclosure-loss analysis ↗
Last verified 2026-07-15
DOCUMENTED FACT C006
Congress granted permanent partial-claim authority and a directed waterfall; it did not write the exclusionary gates.
Active-default, current-servicer, and 3-month-trial requirements are VA design choices in M26-4 Ch.22
Limitation: Codified cite verified: bill Sec. 3(h) = 38 U.S.C. § 3737(h). Confirm UPB/rate caps against M26-4 Ch.22
S010 · H.R. 1815, VA Home Loan Program Reform Act - Pub. L. 119-31 ↗S013 · M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) ↗
Last verified 2026-07-15
DOCUMENTED FACT C007
CARES Act forbearance was universal; only VA borrowers lost their same-rate exit.
Civilian comparison: FHA/Fannie/Freddie kept a permanent same-rate exit
Limitation: Lead argument; confirm the FHA/GSE deferral-exit citation before for-the-record use
S014 · CARES Act forbearance provisions ↗
Last verified 2026-07-15
DOCUMENTED FACT C008
Biden's VA ended the COVID partial claim in Oct 2022; Trump's VA killed VASP in May 2025.
Two-administrations framing; VASP killed effective 5/1/25 on ~8 days notice
Limitation: Foreseeability, not intent; never assert intent to foreclose
Last verified 2026-07-15
DOCUMENTED FACT C009
The VA takes about 75% of foreclosed veteran homes into its REO inventory.
Auction.com data; +428% YoY auction supply
Limitation: Industry data source; confirm current figure
S008 · REO / auction supply data ↗
Last verified 2026-07-15
DOCUMENTED FACT C010
The VA says it helped 173,000 veterans avoid foreclosure in FY2025.
VA's counter-number, stated in its own 6/15/26 launch press release
Limitation: Verified that VA said it, not that 173,000 families kept their homes; lumps forbearances, higher-rate mods and short sales with retention; no bucket breakdown published
S007 · VA program-launch press release (173,000 avoided foreclosure FY2025) ↗
Last verified 2026-07-25
DOCUMENTED FACT C011
The partial claim is not actually available until servicers implement it, deadline Nov 28, 2026.
Two problems, prong 2: until a servicer publishes its own ETA, assume available nowhere
Limitation: Available, not implemented
S006 · VA Partial Claim final policy ↗
Last verified 2026-07-15
DOCUMENTED FACT C012
The VA had separate authority all year to protect families immediately and chose not to use it.
Part 36 tools + Section 3(h); the exclusion of displaced families is reversible without new legislation
Limitation: Preempts VA's 'our hands are tied' deflection
S010 · H.R. 1815, VA Home Loan Program Reform Act - Pub. L. 119-31 ↗S013 · M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) ↗
Last verified 2026-07-15
DOCUMENTED FACT C013
CBO projected $294 million in avoided foreclosure-related payments.
Component of the fiscal case, H. Rept. 119-104
Limitation: CBO estimate over the ten-year scoring window
S005 · CBO score, H. Rept. 119-104 Sec. 3 ↗
Last verified 2026-07-22
DOCUMENTED FACT C014
In November 2025 Congress expanded the Secretary's emergency authority to help veteran families before regulations issue.
Pub. L. 119-37 §7307(e) removed the requirement that a loan have been in default on the day H.R. 1815 was signed; Secretary may issue administrative guidance for the Partial Claim Program and required loss-mitigation options, including any additional terms the Secretary determines necessary (38 U.S.C. §3737(h) as amended; 139 Stat. 651)
Limitation: Statutory text as amended
S019 · Pub. L. 119-37 §7307(e); 38 U.S.C. §3737(h) as amended ↗
Last verified 2026-07-22
DOCUMENTED FACT C015
The program running today operates under exactly this authority: VA's June 1 2026 handbook is pre-regulation guidance invoking the Secretary's §3737 discretion.
M26-4 Ch. 22 is pre-regulation guidance under §3737
Limitation: Agency guidance, pre-rulemaking
S013 · M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) ↗S006 · VA Partial Claim final policy ↗
Last verified 2026-07-22
PROJECT ANALYSIS C016
The Department cannot say it lacks authority to reach the families its eligibility gates exclude; the gates are handbook choices, reversible by the same pen that wrote them.
Authority exists, Congress broadened it, and VA is actively using it for everyone except the families already harmed
Limitation: Interpretation grounded in statute and agency guidance cited
S010 · H.R. 1815, VA Home Loan Program Reform Act - Pub. L. 119-31 ↗S013 · M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) ↗
Last verified 2026-07-22
DOCUMENTED FACT C017
When VASP was cancelled, roughly 75,000 veteran borrowers were three or more payments behind; about 17,000 had been accepted into the program; 58,000+ had no path in.
ICE Mortgage Technology via NPR 4/2/26 and CNN 4/30/25; only a servicer could submit a borrower, not the veteran
Limitation: 58,000+ is derived by subtraction (75,000 minus ~17,000 accepted); labeled derived
S002 · NPR VA foreclosure investigation (Arnold/Lawrence) ↗S020 · VASP behind/accepted figures ↗
Last verified 2026-07-23
DOCUMENTED FACT C018
The partial-claim rule's only borrower-capacity test is whether the veteran can resume the scheduled monthly payment.
38 C.F.R. section 36.4803(d); no resolved-hardship condition (that belongs to the modification rule)
Limitation: Rule text
S021 · eCFR Title 38 Part 36 (VA loan regulations) ↗
Last verified 2026-07-23
DOCUMENTED FACT C019
Loan modifications require a resolved hardship and cap the rate at one percent above the existing rate absent prior VA approval.
38 C.F.R. section 36.4315(a)(2) and (a)(8)
Limitation: Rule text
S021 · eCFR Title 38 Part 36 (VA loan regulations) ↗
Last verified 2026-07-23
DOCUMENTED FACT C020
Regulation X required servicers to evaluate a complete application against all options in 30 days, give a specific reason per denial, and not dual-track.
12 C.F.R. section 1024.41(c)(1),(d),(f),(g); Not Reviewed is not a specific reason
Limitation: Rule text, binding 2022-2026
S022 · eCFR Title 12 section 1024.41 (Regulation X loss mitigation) ↗
Last verified 2026-07-23
DOCUMENTED FACT C021
VA has described its loss-mitigation options as a hierarchy for review, and paid servicer incentives on it, since 2008.
38 C.F.R. section 36.4319(a)
Limitation: Rule text
S021 · eCFR Title 38 Part 36 (VA loan regulations) ↗
Last verified 2026-07-23
DOCUMENTED FACT C022
VA built VALERI to determine servicer compliance and may inspect a servicer's complete delinquent-loan file on request.
38 C.F.R. section 36.4350(j); M26-4 Ch. 5 section 5.11
Limitation: Rule/handbook text
S021 · eCFR Title 38 Part 36 (VA loan regulations) ↗
Last verified 2026-07-23
DOCUMENTED FACT C023
VA's April 2024 launch materials stated it had existing authority to establish VASP under 38 U.S.C. section 3732 and section 3720.
Said twice in April 2024: launch materials, and on the record to HVAC 4/11/24 where Sec. McDonough described VASP as building on existing authority
Limitation: Attribution: launched under Sec. McDonough, terminated 2025 under Sec. Collins; the existing-authority statement is the prior administration's
S023 · VASP launch materials - VA Circular 26-24-16 (existing-authority state ↗S051 · HVAC hearing April 11 2024 - VA budget request FY2025 and FY2026 ↗
Last verified 2026-07-25
DOCUMENTED FACT C024
Post-foreclosure evictions of veteran families are filed in the Secretary's name via a VA REO contractor under a federal contract with a ceiling near $374 million.
VRM REO/eviction contract ceiling (USASpending/FPDS)
Limitation: Contract record; confirm current ceiling
S024 · VRM REO / eviction contract record (PIID VA119A17C0062) ↗
Last verified 2026-07-23
DOCUMENTED FACT C025
The 180-day servicer implementation runway was the mortgage industry's own request, granted in full.
MBA and CHLA each asked VA for at least 180 days in March 2026 comment letters; VA set exactly 180 days from the June 1 publication, landing 11/28/26
Limitation: Industry letters reported by HousingWire 3/12/26; the 180-day figure is confirmed in VA's own servicer FAQ
S026 · Mortgage-industry comment letters on the draft policy (MBA, CHLA) ↗S025 · VA Partial Claim / Loss Mitigation Waterfall FAQs for servicers ↗
Last verified 2026-07-25
DOCUMENTED FACT C026
Foreclosure activity is climbing while the partial claim is still not running.
227,548 filings H1 2026 (+21% YoY, +28% vs H1 2024); VA delinquency 4.99% vs 2.75% conventional; industry forecast of FHA/VA foreclosures more than doubling by autumn 2027
Limitation: ATTOM counts all residential property not veteran households; delinquency is survey data; the doubling figure is a practitioner forecast, cite as warning not projection
S028 · ATTOM 2026 Mid-Year U.S. Foreclosure Market Report ↗S029 · MBA National Delinquency Survey, Q1 2026 ↗S030 · FHA and VA foreclosures could more than double by next fall ↗S033 · US Foreclosures Rise 21% - FHA and VA Loans Show the Most Stress ↗
Last verified 2026-07-25
DOCUMENTED FACT C027
The outcome was named in advance, repeatedly, by the industry, advocates, national press and Congress.
Chronological warning record Mar 2025 - Jul 2026
Limitation: Foreseeability, not intent; never cite as evidence that any official intended the outcome
S009 · 'Foreclosure. Period.' warning (Balce) ↗S020 · VASP behind/accepted figures ↗S030 · FHA and VA foreclosures could more than double by next fall ↗S026 · Mortgage-industry comment letters on the draft policy (MBA, CHLA) ↗S002 · NPR VA foreclosure investigation (Arnold/Lawrence) ↗S034 · Veterans Face Housing Squeeze as VA Pulls Back Help and New Homes Stal ↗S029 · MBA National Delinquency Survey, Q1 2026 ↗S001 · Sen. Blumenthal remarks, SVAC hearing (15,000+ figure) ↗S027 · ABA analysis of the final Ch. 5 / Ch. 22 policy ↗S032 · VA home foreclosures surge as veterans are urged to call servicers ear ↗S028 · ATTOM 2026 Mid-Year U.S. Foreclosure Market Report ↗S033 · US Foreclosures Rise 21% - FHA and VA Loans Show the Most Stress ↗
Last verified 2026-07-25
DOCUMENTED FACT C028
Low-income veteran households get inadequate or no professional legal help for the overwhelming majority of their civil legal problems.
LSC 2017 Justice Gap: 71% had a civil legal problem; sought help for 21%; est. 88% received inadequate or no professional legal help
Limitation: 2017 data, predates this crisis; measures civil legal need generally not foreclosure defence; veteran estimates based on fewer than 100 reported problems
S047 · LSC Justice Gap - Special Focus: Veterans and military personnel (2017 ↗
Last verified 2026-07-25
DOCUMENTED FACT C029
Families who took a COVID-19 forbearance were told, in VA's own guidance, that the missed payments would not have to be repaid in a single payment.
VA CARES Act guidance: up to 180 days + 180 more on request; payments missed during forbearance do not have to be made up in a single payment
Limitation: Guidance as issued in 2020; establishes what families were told, not what any servicer later offered
S048 · VA CARES Act guidance for borrowers with VA-guaranteed home loans ↗S049 · CARES Act Forbearance Fact Sheet for FHA VA and USDA servicers ↗
Last verified 2026-07-25
DOCUMENTED FACT C030
The partial claim veterans used during the pandemic came from CARES Act authority that expired in 2021, leaving VA the only federal home loan program without one.
H.R. 1815 sponsor summary: CARES partial-claim authority expired 2021; every other federal home loan program offers a partial claim except VA
Limitation: Sponsor summary is an advocacy document; cite for legislative rationale on the record, not neutral analysis
S050 · VA Home Loan Program Reform Act of 2025 - sponsor summary ↗S010 · H.R. 1815, VA Home Loan Program Reform Act - Pub. L. 119-31 ↗
Last verified 2026-07-25
DOCUMENTED FACT C031
The bill that creates the VA partial claim also eliminates judicial review of VA's decision to take a secured interest in a veteran's defaulted home loan.
CBO Mandates section: by not allowing judicial review of VA's decision to obtain secured interest in a veteran's defaulted home loan, the bill would eliminate an existing right of action; no cost assigned because judicial review does not result in monetary damages
Limitation: Scores H.R. 1815 as reported in 2025; the authority was enacted via Pub. L. 119-37 s7307 and whether the enacted text carries the same provision is not verified here
S005 · CBO score, H. Rept. 119-104 Sec. 3 ↗
Last verified 2026-07-25
DOCUMENTED FACT C032
The partial claim was scored for roughly 12,200 claims averaging $27,200, with the authority expiring five years after enactment.
CBO: ~12,200 partial claims at $27,200 average on VA-provided loan volume; 37% subsidy rate; $124M subsidy costs 2025-2035; authority expires five years after enactment; 25% cap or 30% if delinquent before May 1 2025
Limitation: 12,200 is a take-up projection, not a statutory cap; scores H.R. 1815 as reported, not enacted Pub. L. 119-37; cohort tiers are counted differently
S005 · CBO score, H. Rept. 119-104 Sec. 3 ↗
Last verified 2026-07-25
DOCUMENTED FACT C033
VA's regulation pays a servicer at most $1,000 for a successful loss-mitigation outcome, and the largest incentive in the schedule is for a short sale.
38 CFR 36.4319(b) incentive schedule by tier: repayment plan 200/160/120/0; special forbearance same; loan modification 700/500/300/0; short sale 1000/800/600/0; deed-in-lieu 350/250/150/0; 36.4319(e) lets the Secretary stop payment for inadequate servicing
Limitation: Incentives are one input into servicer behaviour, not the whole picture; tier ranking is itself a performance mechanism
S021 · eCFR Title 38 Part 36 (VA loan regulations) ↗
Last verified 2026-07-25
PROJECT ANALYSIS C034
The money in VA's rules does not point toward keeping families in their homes.
Top-tier modification pays the servicer $700 while CBO records VA typically pays lenders up to 25% of the outstanding balance on foreclosure (up to $75,000 on a $300,000 balance)
Limitation: Our reading, not rule text; incentive goes to the servicer and guaranty to the holder, often but not always the same company; a guaranty payment reimburses loss rather than producing profit; not a finding that any servicer profits by foreclosing
S021 · eCFR Title 38 Part 36 (VA loan regulations) ↗S005 · CBO score, H. Rept. 119-104 Sec. 3 ↗
Last verified 2026-07-25
DOCUMENTED FACT C035
VA told Congress in February 2024 that it could not offer a partial claim, and explained the risk-share reason why.
VA: unlike HUD and USDA it has no explicit authority to advance guaranty funds as loss mitigation and cannot offer a partial claim pulling from the guaranty; longstanding public position that Congress never authorized a partial advance without termination of the loan; lack of authority may be because VA carries only 25% of default risk where other federal programs carry 90% or more; COVID-VAPCP expired 10/28/2022
Limitation: VA's position as of Feb 2024, before Congress created the permanent partial claim in Pub. L. 119-31 (7/30/25); explains the pre-2025 gap, not VA's authority today
S052 · Written statement of John Bell III, VA Executive Director Loan Guarant ↗
Last verified 2026-07-25
DOCUMENTED FACT C036
VA's own February 2024 numbers: more than 200,000 veterans affected by the COVID-19 emergency, more than 50,000 assisted through its temporary retention options.
Also 145,000+ retained homes and avoided foreclosure over the prior year
Limitation: VA's figures on VA's definitions; the 145,000 covers roughly the year to Feb 2024, a different period and measure from the 173,000 in the June 2026 launch release; cohort tiers are not derived from or merged with either
S052 · Written statement of John Bell III, VA Executive Director Loan Guarant ↗
Last verified 2026-07-25
DOCUMENTED FACT C037
A year before Congress acted, independent analysts had documented that VA had the most limited loss-mitigation options of any federal program and told Congress what was needed.
Urban Institute 7/2024: VA has the most limited loss mitigation options lacking both portfolio and partial claim authority; Congress needs to grant VA partial claim authority and fund a more robust waterfall
Limitation: Independent analysis not a government finding; the paper names funds acquired July 2021 and expired Oct 2022, and the Refund Modification operated on and off after the partial claim authority expired July 2022 - a run of short extensions rather than one end date; this site uses VA's own COVID-VAPCP expiry of 10/28/2022
S053 · Preventing Foreclosures: How the Pandemic Reshaped the Loss Mitigation ↗S052 · Written statement of John Bell III, VA Executive Director Loan Guarant ↗
Last verified 2026-07-25
DOCUMENTED FACT C038
Uneven servicer implementation of VASP was predicted in print, before the harm, because VA never defined the standard servicers had to apply.
Urban Institute 7/2024: lack of clear servicer guidance on 'exhausted all other options' gives servicers a good deal of discretion and assures implementation will be uneven; borrowers could not apply for VASP directly
Limitation: A prediction about VASP as designed in 2024, published before VASP was terminated; evidence of foreseeability not a measurement of servicer behaviour
S053 · Preventing Foreclosures: How the Pandemic Reshaped the Loss Mitigation ↗
Last verified 2026-07-25
DOCUMENTED FACT C039
Analysts noted at the time that VA could have built a more flexible modification under the authority it already had.
Urban Institute 7/2024: VA with its existing authority could have introduced a more flexible modification rather than the flat 2.5 percent; proposed 20-25 percent payment-reduction target with a 2.5 percent floor at lower cost to government
Limitation: Concerns VASP's 2024 design and the scope of VA's existing discretion; not a statement about the June 2026 partial-claim policy whose ceilings Congress set in statute
S053 · Preventing Foreclosures: How the Pandemic Reshaped the Loss Mitigation ↗
Last verified 2026-07-25
DOCUMENTED FACT C040
VA's own borrower FAQ warned that short sale and deed in lieu could result in a loss or reduction in your future home loan benefit.
CARES Act FAQ question 13 attaches the italicised future-benefit caution to short sale and deed in lieu
Limitation: VA's statement of consequence in borrower guidance, not a finding about any family's entitlement
S054 · Information for VA home loan borrowers during COVID-19 - CARES Act fre ↗
Last verified 2026-07-25
DOCUMENTED FACT C041
Both COVID-era partial-claim options were gated on a borrower's status in March 2020 and closed on fixed dates.
COVID-VAPCP 7/27/21-10/28/22, current or within 30 days of current on 3/1/20; Refund Modification 7/27/21-7/1/23, within 120 days current on 3/1/20
Limitation: Records the gates as VA published them, not how many families they excluded
S054 · Information for VA home loan borrowers during COVID-19 - CARES Act fre ↗
Last verified 2026-07-25
DOCUMENTED FACT C042
Entry into CARES forbearance was mandatory on request, without documentation, regardless of whether the borrower was already behind.
Interagency servicer fact sheet: servicer must give the forbearance requested; no documentation required; available regardless of delinquency status; VA servicers cannot require a lump sum immediately on exit
Limitation: The duty attaches to entry and to the lump-sum prohibition on exit; it does not make any exit option mandatory
S049 · CARES Act Forbearance Fact Sheet for FHA VA and USDA servicers ↗S054 · Information for VA home loan borrowers during COVID-19 - CARES Act fre ↗
Last verified 2026-07-25
DOCUMENTED FACT C043
VA instructed servicers not to start foreclosure or its alternatives at Step D, and recorded in the same circular that servicers had been doing exactly that.
Circular 26-24-2: servicer is not to initiate foreclosure or alternatives at this point; VA observed servicers may have begun foreclosure or offered deed-in-lieu or short sale before VA had the opportunity to determine whether another option could help the borrower retain the home; all Step D loans to be referred to VA
Limitation: VA's general observation about servicer conduct under earlier circulars, Feb 2024; not a finding about any individual servicer or loan
S055 · VA Circular 26-24-2 - Updates to VA's COVID-19 Home Retention Waterfal ↗
Last verified 2026-07-25
DOCUMENTED FACT C044
The COVID-19 Home Retention Waterfall's own entry test was broader than the partial-claim test: current or less than 120 days past due as of March 1 2020, or a loan made on or after that date.
Circular 26-24-2 section 5; Step C targets 31 pct of gross monthly household income without VA purchase exceeding 30 pct of UPB, and where achievable the servicer offers the Refund Modification regardless of the percentage of payment reduction
Limitation: The waterfall entry test, distinct from the COVID-VAPCP test in C041; a borrower could fall outside one and inside the other
S055 · VA Circular 26-24-2 - Updates to VA's COVID-19 Home Retention Waterfal ↗
Last verified 2026-07-25
DOCUMENTED FACT C045
In February 2024 VA told servicers it could purchase a delinquent loan outright under its section 3732 refunding authority.
Step D options at VA's sole discretion include exercising loan refunding authority under 38 USC 3732 to purchase a delinquent loan from the holder and assume primary servicing
Limitation: Describes what VA may do at its sole discretion; does not record how often it was used
S055 · VA Circular 26-24-2 - Updates to VA's COVID-19 Home Retention Waterfal ↗
Last verified 2026-07-25
DOCUMENTED FACT C046
The servicer guidance said arrears could be paid back over time, and that a borrower could end a forbearance simply by resuming the regular monthly payment.
Interagency CARES fact sheet: missed payments must be repaid although it may be paid back over time; inform borrowers they can resume making their regular monthly mortgage payment to end the forbearance and discuss repayment options; servicers of VA loans cannot require a lump sum immediately after exit; M26-4 Chapter 5 options
Limitation: Records what the guidance instructed; not a finding that any particular servicer departed from it
S049 · CARES Act Forbearance Fact Sheet for FHA VA and USDA servicers ↗
Last verified 2026-07-25
DOCUMENTED FACT C047
VA named its VASP authority on the record in February 2024, three months before launch: 38 U.S.C. 3732 and 38 C.F.R. Part 4320.
Bell: 'Yes, sir, 38 USC 3732, as an authorization for VASP, as well as our current regulation at 38 CFR 4320'; 40,000 borrowers sought; 6 months of payments required on a modification in the waterfall
Limitation: VA's assertion of authority, contested at the hearing by the subcommittee chair; records what VA claimed and when, not a finding that the authority existed; predates the April 2024 launch materials at C023 by three months
S056 · Hearing transcript, HVAC Subcommittee on Economic Opportunity, Februar ↗
Last verified 2026-07-25
DOCUMENTED FACT C048
The standard was set on the record, by the subcommittee's own chair: whether VA has authority to keep veterans in their homes is a veterans question, not a partisan one.
Van Orden 2/15/24: 'I have concerns now, and I do not care who is in the White House, because this affects our veterans and is not political'; substantive objection was no statutory authority for a below-market-rate modification, very little confidence in VA's ability to administer, VA 'simply making this up'; VA answered 38 USC 3732 and 38 CFR 4320; program terminated eleven months later on ~8 days notice
Limitation: The standard as stated at that hearing, quoted in full and in context; this project applies it to the entire record before and after January 2025 and to every party in it; it does not characterize any member's later positions or motives - what each party said and when is on News & Record and the Accountability Tracker
S056 · Hearing transcript, HVAC Subcommittee on Economic Opportunity, Februar ↗
Last verified 2026-07-25
DOCUMENTED FACT C049
Sixteen months before the replacement was terminated, Congress and VA were already arguing about the interest rate on a modification - from opposite directions.
Chair pressed on intentional default for a lower payment, noting most veteran borrowers exceed 3%; Bell: almost 90% of portfolio at 2.5-3% coupon
Limitation: Hearing record of a policy argument, not evidence about what any servicer offered any borrower; community-reported accounts of market-rate modification offers are recorded separately under their own label and not merged
S056 · Hearing transcript, HVAC Subcommittee on Economic Opportunity, Februar ↗
Last verified 2026-07-25
DOCUMENTED FACT C050
Veterans were told to pay the full arrears or lose the house, after VA had announced a foreclosure pause.
Servicer: you have to pay the full amount back or you're going into foreclosure; pause message did not appear to be trickling down; ~$20,000 arrears
Limitation: Press reporting of one family's account, not a finding about any servicer's conduct generally
S058 · NPR reporting carried by OPB: veterans fear the VA's new foreclosure r ↗
Last verified 2026-07-25
DOCUMENTED FACT C051
The alternative offered in place of a lump sum raised the monthly payment.
Told arrears would move to the back end of a 30-year mortgage; then $57,000 demanded or a modification; modification raised payment $1,300/mo to $3,600
Limitation: One family's reported terms; consistent with C033/C034 but not a pattern on its own
S058 · NPR reporting carried by OPB: veterans fear the VA's new foreclosure r ↗
Last verified 2026-07-25
DOCUMENTED FACT C052
VA active-foreclosure volume diverged from FHA and GSE volumes after the moratorium ended and VA's assistance program ended.
NPR analysis of ICE data indexed to 100 in Jan 2018: VA ~123 by late 2023, FHA ~63, GSE ~55; chart marks VA ending its assistance program
Limitation: News analysis of proprietary servicing data read from the published chart, so index values are approximate
S057 · NPR investigation: veterans face foreclosure after VA ends a COVID for ↗
Last verified 2026-07-25
DOCUMENTED FACT C053
VA's 2023 foreclosure pause was temporary and ran only to May 31, 2024, with 40,000 VA borrowers in foreclosure or delinquent.
Secretary: pause through May 31 2024 for the additional time that we need; 40,000 in foreclosure or delinquent without a modification; VA met with servicers of 90%+ of VA loans
Limitation: Figures as reported Dec 2023; the 40,000 is point-in-time on the reporter's sourcing, not a VA publication, and is not merged with the cohort tiers
S058 · NPR reporting carried by OPB: veterans fear the VA's new foreclosure r ↗
Last verified 2026-07-25
PROJECT ANALYSIS C054
On the government's own numbers, foreclosure is the spending and retention is the offset - the gates that exclude the cohort move federal money to the more expensive outcome.
CBO: decrease in net direct spending, $294M avoided foreclosure-related payments, ~$27,200 per claim; project model ~$2.3B to foreclose on the 31,500 in active foreclosure; 38 CFR 36.4319(b) caps retention incentive at $1,000 with largest incentive for short sale; VA REO eviction contract up to $374.4M
Limitation: Project conclusion, not a government finding; $2.3B is our model from published per-foreclosure figures; CBO scores H.R. 1815 as reported; two of three official statements await Congressional Record or committee-video citation
S005 · CBO score, H. Rept. 119-104 Sec. 3 ↗S003 · NCLC analysis to HVAC EO Subcommittee (Cohen) ↗S021 · eCFR Title 38 Part 36 (VA loan regulations) ↗S024 · VRM REO / eviction contract record (PIID VA119A17C0062) ↗
Last verified 2026-07-25
DOCUMENTED FACT C055
The committee that ended VASP argued for the partial claim on cost grounds - and put the arithmetic on the record.
Apr 3 2025 joint statement: intent to establish a partial claim so veterans can stay in their homes 'while still protecting the American taxpayer'; $22,500 average delinquency vs $292,000 average loan purchased (now $320,000); a partial claim 'could solve the majority of delinquent loans at a much less expensive clip to the taxpayer'
Limitation: The quoted words and figures are the committee majority's own; establishes the standard its authors set for themselves; the characterisation of why VASP was created is theirs, quoted not adopted
S059 · Chairman Bost, Van Orden Issue Joint Statement on Phase Out of VASP Pr ↗
Last verified 2026-07-25
PROJECT ANALYSIS C056
Measured against the standard its own authors set, the partial claim has not yet done what it was said to do.
VASP ended 5/1/25 on ~8 days notice; partial claim authorised 7/30/25, final policy 6/1/26, submissions 6/15/26, servicer deadline 11/28/26 - more than 18 months; Ch. 22 handbook gates exclude the cohort the withdrawal exposed; CBO scored the partial claim as a decrease in net direct spending against ~$2.3B modelled for the 31,500 in active foreclosure
Limitation: Project conclusion from the cited record, not a government finding; dated commitments measured against dated implementation; establishes that commitment and outcome diverged and who made the commitment, not why; $2.3B is this project's model
S059 · Chairman Bost, Van Orden Issue Joint Statement on Phase Out of VASP Pr ↗S010 · H.R. 1815, VA Home Loan Program Reform Act - Pub. L. 119-31 ↗S006 · VA Partial Claim final policy ↗S013 · M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) ↗S005 · CBO score, H. Rept. 119-104 Sec. 3 ↗S003 · NCLC analysis to HVAC EO Subcommittee (Cohen) ↗
Last verified 2026-07-25
DOCUMENTED FACT C057
Within six days of the VASP announcement, the ranking members of three committees of jurisdiction warned the Secretary in writing that the closure would push veterans into foreclosure.
Apr 9 2025 letter signed by 22 Democrats and Independents; Takano's 80,000 figure the same month; Jul 2025 bipartisan bicameral statement describing the replacement as a tool to keep veterans in their homes
Limitation: Statements of the members who made them, quoted as made; the 80,000 figure is Takano's and is not adopted or merged with the cohort tiers
S060 · Blumenthal, Warren & Takano to Collins: Stop Pushing Thousands of Vete ↗S061 · Ranking Member Takano statement on the termination of VASP ↗S062 · Senate and House VA Committee leaders' statement on passage of the VA ↗
Last verified 2026-07-26
DOCUMENTED FACT C058
The Take Care of America's Veterans Act is paid for by raising VA home loan fees and by codifying future disability-rating cuts.
IRRRL funding fee 0.5% to 1.42%; loan-assumption fee 0.5% to 1.0%; Section 108 codifies an estimated $57B in future rating reductions for tinnitus and sleep apnea; Common Defense estimates $8,000+ added over an average loan; VFW and DAV oppose the offsets; led by Reps. Bost and Van Orden and Sen. Moran
Limitation: Records the offsets as written and the organisations' stated opposition; asserts no member's motive; the site's reading is labelled FACTUAL ANALYSIS separately
S031 · VA home loan refinancing fee would nearly triple under GOP-led bill ↗S041 · Take Care of America's Veterans Act (H.R. 9237), 119th Congress - bill ↗
Last verified 2026-07-26



































