The record, the authority, and the cost
Legal & policy analysis
The three-layer rule
This page keeps three layers visibly distinct: documented authority (statute, regulation, VA manual, hearing record), factual analysis (our source-supported reading), and community-reported illustration (a consented, de-identified household experience). We never let one stand in for another, every label on this site is defined at Data & Methods →
Part 1
The record, in order
What each party said and did, in sequence, from the promise made in 2020 to the policy that is final but not yet operational everywhere. Every entry is a primary document or a dated report.
2020 · The promise
Source S049 · claims C042, C046
What VA told servicers to do
These pages are from the interagency fact sheet for servicers of FHA, VA and USDA loans (S049). The document that told servicers what they could and could not require of a borrower leaving a CARES Act forbearance. It is reproduced here because the instructions are unambiguous and were published to the servicers themselves.
Open full capture ↗
2020 · The repayment instruction
Paid back over time, not in a lump sum
The repayment instruction, in the servicers’ own guidance: missed payments “must be repaid, although it may be paid back over time,” and servicers are to inform borrowers they can “resume making their regular monthly mortgage payment to end the forbearance, and discuss what repayment options are available.” Evidences C046.
2020 · VA loans specifically
No lump sum on exit from forbearance
The VA-specific instruction: servicers of VA loans “cannot require borrowers to make a lump sum payment immediately after a borrower exits a CARES Act forbearance,” and are pointed to the Chapter 5 loss-mitigation options in the M26-4 servicer handbook. Evidences C042, C046.
2023 · The interim, no partial claim, no replacement.
What happened in the years with no partial claim
The COVID partial claim expired October 28, 2022 (S052). VASP did not launch until May 2024. National reporting in late 2023 documented what veteran families were being told in that gap, by NPR (S057) and in NPR reporting carried by OPB (S058).
Claims resting on this reporting: C050, C051, C052, C053
These are copyrighted news reports, not government documents. The two family accounts are quoted briefly under fair use and linked to the publishers, with no article pages reproduced. NPR’s chart is reproduced as the cited source for C052, credited to NPR and ICE Mortgage Technology in the caption.
Open full capture ↗
VA foreclosures diverged from every comparable program. NPR’s analysis of ICE Mortgage Technology data indexed active foreclosure volume to 100 in January 2018: after the CARES moratorium ended, the VA index rose above its 2018 level to roughly 123 by late 2023, while the FHA index fell to about 63 and the GSE index to about 55. The chart marks the point where VA ended its mortgage assistance program. VA was the only one of the three without a partial claim.
NPR analysis of ICE Mortgage Technology data · S057 (C052)
Veterans were still being told to pay the full arrears or lose the house, after VA had announced a foreclosure pause. One veteran told NPR he read that VA was pausing foreclosures so families like his could get help; his servicer, Mr. Cooper, told him “you have to pay the full amount back or you’re going into foreclosure.” The report notes the pause message “did not appear to be trickling down” to mortgage-company staff. The same family faced about $20,000 in missed payments after a decade in the Marine Corps and four combat tours.
Reported by NPR, carried by OPB · S058 (C050)
The alternative offered in place of a lump sum raised the payment. A veteran was told the missed payments would move to the back end of a 30-year mortgage; in September he was told the deal had changed and he owed $57,000 or could take a modification. He could not pay it, and the modification raised his payment by $1,300 a month, to $3,600, first payment due the day the article ran. This is the same pattern VA’s own incentive schedule points at (C033, C034).
Reported by NPR, carried by OPB · S058 (C051)
The pause was temporary, and it was not a remedy. VA’s Secretary said the pause would run “through May 31 next year, 2024” to give VA “the additional time that we need” to help veterans stay in their homes. At that point 40,000 VA borrowers were in foreclosure or delinquent without a modification. The Secretary also said VA had met with servicers of more than 90% of all VA loans and that they would comply.
Reported by NPR, carried by OPB · S058 (C053)
February 2024 · Congress asks whether VA has the authority.
Hearing record · February 15, 2024 · S056
What Congress and VA said to each other before any of it happened
You may have heard: “VASP was cancelled because it was illegal” →
Three months before VASP launched, and fourteen months before it was terminated on May 1, 2025, the House Veterans’ Affairs Subcommittee on Economic Opportunity questioned VA about it directly. The subcommittee’s chair set the standard for that scrutiny in his own words. “I have concerns now, and I do not care who is in the White House, because this affects our veterans and is not political”, and pressed VA to name the statute it was relying on. This project applies that standard to the whole record, before and after January 2025, and to every party in it. The pages below are reproduced from the transcript.
Asked to name the statute, VA named it. Pressed to “provide us right now with specific authorities outlined in statute,” VA’s Executive Director of Loan Guaranty Service answered: “Yes, sir, 38 USC 3732, as an authorization for VASP, as well as our current regulation at 38 CFR 4320.” VA said it was “looking for a solution to be able to help 40,000 borrowers stay off foreclosure,” and that its own protocols required six months of mortgage payments on a modification within the loss-mitigation waterfall. That is VA asserting existing authority three months before the April 2024 launch materials already cited here.
The interest rate on a modification was already the argument, from the opposite direction. The subcommittee pressed VA on whether veterans might “intentionally default in order to receive a lower payment,” observing that “most veteran borrowers have an interest rate exceeding 3 percent.” VA replied that “almost 90 percent” of its portfolio sat at a 2–1/2 to 3 percent coupon rate. In February 2024 the objection to the rescue program was that its rate was too low. Fourteen months later, on May 1, 2025, the program was terminated on roughly eight days’ notice, and the authority question raised here became the question the whole record turns on.
February 2024 · The authority question
Asked on the record, answered on the record
Hearing 118-53, February 15, 2024, the authority question and the answer. Evidences C047 (VA names 38 U.S.C. §3732 and 38 C.F.R. 4320) and C048 (the “I do not care who is in the White House” standard, shown in the paragraph that sets it). Source: S056.
February 2024 · The rate exchange
The objection, in full and in context
Hearing 118-53, February 15, 2024, the rate exchange in full. Evidences C049: in February 2024 the objection was that the rescue rate was too low. Source: S056.
July 2024 · Before the law existed
The gap was documented in public a year before Congress acted
You may have heard: “VASP was cancelled because it was illegal” →
What this section is: eight pages from one public study, the Urban Institute’s Housing Finance Policy Center, July 2024 (S053), reproduced in full so the wording can be checked against the claims it supports.
Why it is here: it was published twelve months before Congress created the permanent partial claim on July 30, 2025, and ten months before VASP was terminated on May 1, 2025. It already named the authority gap, the undefined servicer standard, and the fact that a standard modification raises most VA borrowers’ payments. None of that was discovered afterwards. It was on the record, from a mainstream housing-finance analyst, in time to act on.
Claims resting on these pages: C037, C038, C039
Ordered by the event each page describes, not by page number.
March 2020
The promise made to families
Urban Institute, July 2024. What families were offered. Forbearance for up to 12 months on all federal mortgages including VA, requested by simply informing the servicer of a COVID-19 hardship, with deferral to the end of the loan among the exit options. This is the promise at the start of the chronology; C029 carries VA’s own version of it.
Jul 2021 – Oct 2022
The partial claim appears, then expires
Urban Institute, July 2024, “VA Loss Mitigation Programs.” The source for C037: “the VA has the most limited loss mitigation options, lacking both a portfolio and partial claim authority.” This page also carries the funding chronology, partial-claim funds acquired July 2021, expired October 2022, the Refund Modification then “operated on and off” through a series of extensions to May 2024. VA’s own date for the COVID-VAPCP expiry is October 28, 2022 (S052); the July 2022 date later in this same paragraph refers to the partial-claim authority behind those extensions.
May 2024
The stopgap VA built instead
Urban Institute, July 2024, why the alternatives did not work. “For most VA borrowers, a loan modification will increase their payment, as the prevailing market rates are higher than the rates at loan origination,” which is why VASP was “the only option” for most. Context for C039 and for the modification terms families were offered after forbearance.
May 2024
Why a standard modification does not help
Urban Institute, July 2024, VASP as designed: purchase, 2.5 percent, a 20 percent payment-reduction floor, 40-year term if needed, described as “more generous than the one the GSEs offer.” The named weaknesses are the absence of a deferral option and the transfer of every acquired loan to a single VA servicer. The February 2024 subcommittee hearing referenced here is S052.
In the same paper
The standard nobody defined
Urban Institute, July 2024, the prediction, in print. The source for C038: the interpretation of “exhausted all other options” was undefined, which “gives servicers a good deal of discretion and assures that implementation will be uneven.” The same page records that veterans could not apply for VASP themselves, servicers screened and identified them, and, for C039, that “the VA, with its existing authority, could have introduced a more flexible modification.”
The recommendation
What they told Congress to do
Urban Institute, July 2024. The recommendation. “Congress needs to grant the VA partial claim authority and allocate funding to establish a more robust loss mitigation waterfall framework similar to what GSE and FHA borrowers currently access.” Published a year before Pub. L. 119-31. The costed alternative above it, a 20 to 25 percent payment-reduction target with a 2.5 percent floor, at lower cost to the government, supports C039.
The conclusion
In their own words
Urban Institute, July 2024, conclusion. “The VA, operating within the constraints of its legislative authority, has introduced the VASP program … The VA would benefit from more legislative authority.” The authority gap stated as a finding, not an advocacy position.
Scale of the cohort
How many forbearances there were
The same report charts the size of the pandemic forbearance cohort: 8.8 million forbearances, most of them resolved, performing, paid off, or modified, and a much smaller number still unresolved when the paper went to print, including 101,000 in active foreclosure and 103,000 in delinquency without a loss-mitigation plan.
Urban Institute, July 2024, Figure 1, the scale of the pandemic forbearance cohort: 8.8 million forbearances, of which 101,000 were in active foreclosure and 103,000 in distressed liquidation as of February 2024. Limit: these are all federal and GSE mortgages, not VA loans, and are not broken out by program, no figure on this site is derived from this chart. It is included to show the size of the population the pandemic waterfall was managing.
The statutes, circulars and guidance, in order
Filtered to the authority layer: what was written, by whom, and when.
March 2020
CARES Act forbearance begins. Federal agencies issue written guidance to FHA, VA and USDA servicers stating paused payments are repaid over time and a lump sum is not required.
Documented fact S049
Apr 23, 2025
VBA Circular 26-25-2 issued, announcing the VASP program wind down.
Documented fact 26-25-02
Jul 30, 2025
H.R. 1815 signed into law, unanimous in both chambers. Creates the Partial Claim Program at 38 U.S.C. 3737. Section 3737(h) permits the Secretary to act by administrative guidance before regulations.
Documented fact Source
Nov 12, 2025
38 U.S.C. 3737 amended by Pub. L. 119-37, div. G, title III, sec 7307(b) to (e). The 3720(h) foreclosure protection is narrowed.
Citation pending
Jun 1, 2026
VA issues final partial claim policy: M26-4 Chapters 5 and 22. Ten qualifying criteria in section 22.02, seven of which do not appear in 38 U.S.C. 3737.
Documented fact
These entries are set in the page. The full chronology, with every dated entry and its source, is on the Timeline.
Part 2
What follows from the record
The authority that exists, what the Department has said about it, what “helped” is being made to mean, and what the arithmetic shows. These sections read the record above rather than adding to it.
Congress wrote three conditions. The handbook lists ten.
Seven of the ten eligibility rules for the VA Partial Claim Program appear nowhere in the law Congress passed.
Key finding · who wrote the gates
Documented factCongress created the Partial Claim Program at 38 U.S.C. § 3737 in July 2025 with a three-condition eligibility test. VA’s implementing handbook, M26-4 Chapter 22, effective June 1, 2026, lists ten qualifying criteria. Seven do not appear in the statute. Removing them requires no new legislation, only the same discretion VA used to add them.
Limit: this compares the text of the statute with the text of the handbook. It establishes that seven criteria are agency additions, not that any one of them is unlawful.
The seven criteria that appear only in the handbook
- M26-4 § 22.02 a.2
- M26-4 § 22.02 a.4
- M26-4 § 22.02 a.5
- M26-4 § 22.02 a.6
- M26-4 § 22.02 a.7
- M26-4 § 22.02 a.8
- M26-4 § 22.02 a.9
Compare 38 U.S.C. § 3737 (statutory eligibility) with M26-4 Chapter 22 § 22.02 (handbook criteria), effective June 1, 2026.
Rulemaking · the comment window
Two criteria were added after the public comment window closed.
People who commented on the draft, including veterans service organizations, commented on a different document. The February 2026 draft required six payments since the most recent modification. The final replaced that with a flat 24 month modification lockout, and added a tenth criterion that does not appear in the draft at all.
M26-4 Chapter 22, February 2026 draft compared with the June 1, 2026 final · Documented fact
One claim per loan · scope
The statute limits one claim per loan. The handbook extends that to a different program.
Borrowers who used COVID era help exactly as instructed are now disqualified from the program meant to replace it. 38 U.S.C. § 3737(c)(2)(A) provides that the Secretary may make only one partial claim per loan. By its terms that limit applies to claims under that section. Handbook criterion 10 extends the disqualification to a COVID-19 Veterans Assistance Partial Claim Payment, made under 38 C.F.R. part 36 subpart F and a separate authority, and to a COVID-19 Refund Modification. Neither is a § 3737 partial claim.
38 U.S.C. § 3737(c)(2)(A); M26-4 § 22.02 criterion 10 · Documented fact
Interim authority · § 3737(h)
Congress gave VA authority to act before final rulemaking.
The law says VA can issue guidance now, without waiting. Section 3737(h) expressly authorizes administrative guidance in advance of regulations, notwithstanding any other provision of law. We have found no published § 3737(h) guidance.
38 U.S.C. § 3737(h) · Documented fact, with a stated negative: no published guidance located as of July 29, 2026
What counts as help · the 173,000 number.
“Helped 173,000 avoid foreclosure”. Ask what counts as help
Rebuttal in one line: families they processed, not families they saved
The VA’s own figure lumps four very different outcomes together. Three of them are temporary or lossy. Only one means a family kept its home, and the VA has not published how large that bucket is. The number is now pinned to VA’s own launch press release, which says VA “worked with mortgage servicers to help 173,000 Veterans” in FY2025. What that verifies is that the VA said it, not that 173,000 families kept their homes. These buckets are shown as labeled categories, not to scale.
Bucket 1
Temporary forbearances
Counted by the VA as “avoided foreclosure.” A pause, not a cure. The arrears are still owed when it ends.
Bucket 2
Higher-rate modifications
Counted by the VA as “avoided foreclosure.” The family keeps the house at a payment higher than the one they could not pay.
Bucket 3
Short sales & deeds in lieu
Counted by the VA as “avoided foreclosure.” The family loses the home. It is a foreclosure alternative, not a family kept in place.
Bucket 4
Permanent home retention at a sustainable payment
The only bucket that means a family kept its home. Its size is unknown. The VA has not broken the total down.
Why resuming payments does not solve it
Families want to resume paying. This sets out the rules that stop a servicer from letting them.
Read the full record (473 words)
They want to. The system won't let them. When a VA loan is in default, the servicer will not accept regular monthly payments. They demand full lump-sum reinstatement, all missed payments, interest, fees, and escrow, upfront, in full, before any conversation. For a family that entered COVID forbearance, that's $35,000+. The partial claim takes that $35,000, places it in a second lien, resets the loan to current, and lets the family resume their regular monthly payment.
We called Freedom Mortgage a month before our forbearance ended to make sure we did everything right before resuming payments. We found out the COVID program had been cancelled, no notice, no plan, no path to restart. We are not asking for a handout. We are not asking for free mortgage payments. We are asking to be allowed to pay our mortgage.
Every safety net is down, simultaneously.
- Not yet requiredH.R. 1815 Partial ClaimSigned into law July 2025. VA says it was available and live on June 15, 2026. Servicers are not required to offer it until November 28, 2026.
- TransitionBRAVE (replacing HUD-VASH)Senate didn't fund. House funded $970M of $1.1B requested. Not operational. No transition timeline.
- LapsedEmergency Housing VouchersFunding ran out in March 2026. 59,000 households losing assistance. Was supposed to last until 2030.
- EliminatedUSICHFederal coordinating body for homelessness response. Eliminated in FY2026 budget. No replacement.
- UncertainSSVFPrimary program for veteran families at risk. Future uncertain under BRAVE restructuring.
- Coercion trackProject Safe HarborVA initiative being piloted in greater Los Angeles using the guardianship system as an intervention pathway. Project documents cited by Rep. Delia Ramirez (D-IL) at the 5/13/26 HVAC oversight hearing describe enrolling veterans "on the streets" as well as those already in care; VA's representative at the same hearing characterized the program as focused on hospitalized veterans lacking mental capacity for decision-making, and described earlier documents as outdated. The dispute is on the record. Either way, this is a guardianship-based involuntary-intervention pathway running in parallel to the safety-net programs being defunded above, coercion is not a substitute for the partial claim, housing vouchers, or homelessness coordination this list documents are missing. Source: 5/13/26 HVAC NCWI oversight hearing, ~1:27:35 mark.
Each change has a rationale. But when you zoom out: there is no functioning safety net for veteran families in foreclosure right now. Not one. You don't fix bureaucratic dysfunction by creating more bureaucratic dysfunction without a transition plan. Veterans understand phased operations. This isn't one.
GAO is documenting the pattern. GAO-26-107517 (3/30/26): 174,045 veterans not referred to HUD-VASH supportive housing 2020–2024; VA failed to document any reason in 87% of cases. GAO-26-108943 (3/4/26) and GAO-26-108070 (4/16/26): parallel implementation gaps in VA caregiver support tied to the Elizabeth Dole Caregiver Act. Same agency. Same non-implementation pattern. Different programs, same outcome for veteran families.
The fiscal case · what each outcome costs
Foreclosure is the most expensive outcome, for everyone
You may have heard: “VASP was cancelled because it was illegal” →
You may have heard: “why can’t they just start paying again” →
The fix Congress already passed converts arrears a foreclosure would write off into a zero-interest second lien, repaid when the veteran sells or refinances. It is funded by the Loan Guaranty Fund, veteran funding fees, not taxpayer appropriations. The family stays housed and the loan keeps performing. Foreclosure does the opposite, at far greater public cost.
Key finding
PROJECT ANALYSISSet that schedule against what the same regulation pays when the home is lost. CBO records that VA “typically pays lenders up to 25 percent of the outstanding mortgage balance if a borrower’s home is foreclosed upon.” On a $300,000 balance that is up to $75,000 through the guaranty; the same file worked to a successful modification pays $700. This project’s reading is that the money in the rules does not point toward retention, and that a policy relying on servicer initiative to reach families in default is relying on the weakest financial signal in the file.
The crisis right now
DOCUMENTED FACT$0
Zero-interest second lien, no cash out the door.
Loan Guaranty Fund, not appropriations
Scale it to the crisis
$2.3B
Projected cost of foreclosing on 31,500 veteran families.
72%
of the VA’s FY25 homeless-programs budget ($3.2B enacted; $3.46B requested for FY26).
By the VA’s own accounting, only about a quarter of that budget goes to prevention, and none of it prevents a foreclosure. The programs those families land in are already failing them. See the housing analysis →
The fiscal-responsibility rebuttal
Foreclosure is the spending. Retention is the offset.
The program was cut, and the gates written, on a stated concern for cost and program integrity. The record scores it the other way: the outcome the gates produce is the one that costs the Treasury more.
Congress’s own scorekeeper priced retention as the cheaper outcome. CBO scored the permanent partial claim as a decrease in net direct spending, with $294 million in avoided foreclosure-related payments, at a subsidy cost of roughly $27,200 per claim. Against that, this project’s model puts the cost of foreclosing on the 31,500 veteran families currently in active foreclosure at about $2.3 billion. Every gate that moves a family from partial claim to foreclosure moves federal money from the smaller number to the larger one.
S005 · S003 · claim register (C054; builds on C004, C013, C032)
The money that does flow is on the disposition side. 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, not a retention. Meanwhile post-foreclosure evictions are filed in the Secretary’s name by a VA contractor under a federal contract worth up to $374.4 million. Federal dollars are budgeted to take the house; the retention incentive is capped at four figures.
The fiscal argument for the partial claim is the committee’s own. Announcing the VASP phase-out on April 3, 2025, the HVAC Chairman and the Economic Opportunity Subcommittee Chairman wrote that the action “underscores House Republicans’ intent to establish a partial claims program at VA to ensure veterans’ can stay in their homes if they’re in financial hardship while still protecting the American taxpayer.” The statement sets out the arithmetic: “Instead of reinstituting the partial claim program for an average loan delinquency of $22,500VA chose to purchase these loans through the VASP program at an average of $292,000”, since risen to $320,000, and says a partial claim “could solve the majority of delinquent loans at a much less expensive clip to the taxpayer.”
S059 (C055)
Held to that standard, the record reads against it. VASP ended May 1, 2025, on roughly eight days’ notice. The partial claim was authorised July 30, 2025; its final policy published June 1, 2026; submissions opened June 15; servicers have until November 28, 2026, more than eighteen months after the tool it replaced was withdrawn. And the handbook gates in Chapter 22 exclude families whose default or foreclosure fell inside that window, the cohort the withdrawal exposed. The cheaper option was named in advance by the people who ended the expensive one; the families it was named for are the ones it does not reach.
S059 · S010 · S013 · claim register (C056; builds on C015, C016)
Limit. The $2.3B figure is this project’s model from published per-foreclosure cost figures, not a government estimate, and the CBO numbers score H.R. 1815 as reported. The April 2025 joint statement is quoted from the committee’s own press release, and named here because its authors set the standard this section measures. Its characterisation of why VASP was created is theirs, quoted rather than adopted. Further statements by named officials are recorded and dated on the Accountability Tracker, where any still awaiting a Congressional Record or committee-video citation are labelled.
What a servicer is paid to save the home.
38 C.F.R. § 36.4319(b)
The full servicer incentive schedule
38 C.F.R. § 36.4319(b) on eCFR, the full servicer incentive schedule by tier ranking. Evidences C033; the comparison drawn at C034 is this project’s reading, not rule text.
The incentive VA pays a servicer for a successful loss-mitigation outcome is set in regulation, and it is small. Under 38 C.F.R. § 36.4319(b), a completed repayment plan pays $200, a loan modification $700, a short sale $1,000, and a deed-in-lieu $350, at the top tier. Those amounts step down by servicer tier ranking and reach $0 at Tier Four. Nothing in the schedule pays more for keeping a family in the home than for disposing of it: the largest single incentive in the table is for a short sale.
Two limits on the comparison above. The incentive is paid to the servicer; the guaranty payment goes to the holder of the loan, which is often but not always the same company. And a guaranty payment reimburses a documented loss. It is not profit. The asymmetry is in what each path pays out, not a finding that any servicer profits by foreclosing.
Two paths, one family, three-year government cost
PROJECT ANALYSISPath A
What happens now, foreclosure
Path B
What H.R. 1815 does, partial claim
** Model built from the NCLC and CRL per-foreclosure cost figures (S003/S004), the Auction.com REO share (S008), NIH/PMC homeless-cost studies, CRS SSVF data, and the VA FY25 budget. Illustrative of one family; figures are estimates, labeled as analysis.
The VA isn’t just a guarantor anymore
DOCUMENTED FACT75–80%
of foreclosed veteran homes pass into the VA’s own REO inventory. Source: Auction.com.
Every foreclosure makes the VA the 100% owner
Sec. Collins, Rep. Bost, and Rep. Van Orden frame this around fiscal responsibility and cutting government waste, and argue the VA has no business owning mortgages. It already does. The VA lends directly through the Native American Direct Loan program, and roughly three in four foreclosed veteran homes move into the VA’s own REO inventory, where it becomes the sole 100% owner, not a guarantor. Foreclosure does not get the government out of the mortgage business. It puts the government on the hook for the entire house, then for the cost of the family it displaced.
On the record: Sec. Collins told the Senate the VA “shouldn’t be in the real estate business… that was not statutory.” Foreclosure is exactly what puts it there, at the direct loss shown above, versus the ~95% the VA recovered by holding the loan under VASP. Rep. Mark Alford (R-MO), Congressional Real Estate Caucus co-chair, put that inversion to the VA directly.
“Why can’t veterans just start paying again?”
They want to. The system won’t let them. When a VA loan is in default, the servicer will not accept regular monthly payments, it demands full lump-sum reinstatement (every missed payment, plus interest, fees, and escrow) upfront. For a family that entered COVID forbearance, that is $35,000 or more. The partial claim takes that balance, places it in a second lien, resets the loan to current, and lets the family resume its regular monthly payment.
The partial claim, scored
$147M
decrease in net direct spending over ten years (CBO; H. Rept. 119-104), driven by $294M in avoided default-related payments on guaranteed loans. Section 3 alone scores at −$170M. The same table authorizes $148M subject to appropriation, so the saving sits on the mandatory side of the budget. Even before the human cost, the fix is the cheaper option on paper.
S005 (C004, C013)
What the score also says
Five pages of the CBO estimate, and what each one is for
Congress’s own scorekeeper priced this bill before it passed. The two findings below rest on the pages reproduced beneath them, the terms and volume CBO assumed, the savings it projected, the budget table those savings come from, and the right of action it recorded the bill removing. Each capture is labelled with the section of the estimate it comes from and the claim it supports.
The CBO cost estimate for H.R. 1815 records, under Mandates, that by not allowing judicial review of the Department of Veterans Affairs decision to obtain secured interest in a veteran’s defaulted home loan, the bill “would eliminate an existing right of action” for any public or private entity that would otherwise be able to seek judicial review. CBO assigns the mandate no cost “because judicial review does not result in monetary damages.”
S005 · CBO estimate, H. Rept. 119-104 · claim register (C031)
Using VA-provided loan-volume data, CBO expected VA to pay roughly 12,200 partial claims at an average of $27,200 over the course of the program, with a 37% subsidy rate and $124 million in subsidy costs over 2025–2035. The estimate also records that the program authority would expire five years after enactment, and that claims are capped at 25% of the outstanding balance, or 30% for borrowers delinquent before May 1, 2025.
S005 · CBO estimate, H. Rept. 119-104 · claim register (C032)
C032
What CBO assumed the program would be
CBO cost estimate, H.R. 1815, program terms and projected volume: the 25 / 30 percent ceilings and the May 1, 2025 delinquency trigger, the five-year sunset, and the 12,200 claims at $27,200. Evidences C032; corroborates the 30 percent trigger cited at C015.
C013
The savings CBO projected
CBO cost estimate, H.R. 1815, “Other Loan Effects.” The $294M in avoided default-related payments and the −$170M for section 3 alone. Evidences C004 and C013.
C019
Both spending lines, in one table
CBO cost estimate, H.R. 1815, Table 1. The −$147M is the direct-spending line; the table separately shows $148M authorized and $146M outlaid subject to appropriation. Both figures are on the same page, which is why this project states the saving as a decrease in net direct spending rather than a saving across the whole budget.
C034
What VA already pays when a home is lost
CBO cost estimate, H.R. 1815, “Partial Claim Program.” Background for the two findings above: VA already pays lenders up to 25 percent of the balance when a home is foreclosed, from the same mandatory account the partial claim would draw on. Context, not a claim of its own.
C031
The right of action the bill removes
CBO cost estimate, H.R. 1815, “Mandates.” The judicial-review elimination, in CBO’s words. Evidences C031.
Everyone got the same COVID help. Only veterans got trapped. CARES Act forbearance was universal, and FHA, Fannie Mae, and Freddie Mac all kept a permanent same-rate exit. Only VA borrowers lost theirs. Read the full chronology on the timeline, or the current status on what is happening.
Why the cost argument runs the same in both directions
The cost argument for keeping families in their homes holds whether you start from fiscal restraint or from equity.
You may have heard: “helping them would cost taxpayers more” →
Read the full record (581 words)
The H.R. 6047 funding-fee debate sounds, from the floor, like a routine partisan offset fight. It is not. Both Ranking Member Takano and the Democratic caucus have repeatedly made clear they support the underlying benefit increases for catastrophically disabled veterans and Gold Star survivors. The disagreement is about long-term program viability, exactly the fiscal-responsibility frame Republicans usually invoke.
Rep. Mark Takano spelled out the argument at the HVAC Full Committee Legislative Hearing on May 20, 2026, and the math is the math, regardless of party:
"Many of the items on the agenda will have a cost. The majority has promised some kind of magic coupons that will be available if we just sunset everything after two years or take money away from other programs. That is hardly a responsible reauthorization process. Also, let's consider reality. The majority is putting a $4 billion bill on the floor this week that consumes all of the committee's offsets and then some. The chairman and Mr. Barrett are raising fees on financially distressed veterans to pay for some of it. And on top of that, we still have to pass our annual extenders bill that will also have a cost. So I again ask where will the money to pay for today's legislation come from for the fees and taxes on veterans' earned benefits? I do not think it's fair or responsible to engage in a convoluted legislative process when there's no realistic pathway to get most if any of these bills done."
Rep. Mark Takano (D-CA-39), HVAC Full Committee Legislative Hearing, May 20, 2026 (YouTube, HVAC Dems channel, ~30:39)
The "magic coupons" framing is the key. The H.R. 6047 funding-fee offset consumes the committee's entire offset capacity for the 2026 session. Every other veteran benefit bill, every reauthorization, every program update the committee wants to pass for the rest of the year now has to either find its own offset, compete with H.R. 6047's offset for the same money, or get pulled from the agenda altogether. The pattern is documented: at the HVAC 5/20 hearing alone, four foreclosure- and benefit-adjacent bills were pulled from the originally-noticed agenda before witnesses were called, including H.R. 1732, the GUARD VA Benefits Act (Pappas). VFW Director Kristina Keenan confirmed at the hearing that VFW strongly supports H.R. 1732 and that "every day that it doesn't [move forward], unaccredited claim sharks continue to exploit veterans and their benefits." Also pulled: H.R. 4876 (Brownley, Reproductive Freedom for Veterans Act, with Brownley confirming the removal at the hearing), H.R. 6755 (Accountable Leadership for Veterans Act), and H.R. 6861 (Consolidating Veteran Employment Services Act, listed as bill #11 in MRC Desmond's prepared written testimony, meaning the bill was on the docket late enough that the witness prepared content for it before Bost pulled it).
This is what Republicans usually call fiscal irresponsibility: committing all your offset revenue to one purchase and then promising future spending you have no plan to fund. The offset Republicans chose to fund H.R. 6047 with is being applied to the exact population currently absorbing the foreclosure crisis: 15,000+ veteran families have already lost their homes since VASP termination, 90,000 more are in foreclosure right now, and no § 3737(h) administrative guidance has been published. Adding compound-interest mortgage fees to the same families the federal government is failing to protect from foreclosure is not fiscal responsibility. It is fiscal compounding of a crisis the same Congress is supposed to be solving.
Foreseeability · who warned, and when
Nobody can say they weren’t warned
This is the part that cannot be explained as an unforeseen consequence. The mortgage industry, consumer advocates, national press, the Department’s own trade counterparties and the ranking members of the three congressional committees of jurisdiction, in a letter signed by 22 members. Each said, on the record and in advance, what would happen if the safety net came down before a replacement was running. Congress then said, on passage, what the replacement was for. The record below is chronological. Every line is a source already in this register.
Mar 2025
Mortgage Bankers Association
Warned that stripping the protection would end in one place for many veterans: “Foreclosure. Period.”
Blumenthal, Warren and Takano, to Secretary Collins
Six days after the announcement, the ranking members of the Senate Veterans’ Affairs, Senate Banking and House Veterans’ Affairs committees wrote to the Secretary in a letter signed by 22 Democrats and Independents: the closure was “leaving tens of thousands of veterans at risk for foreclosure… We write today to urge you to immediately reverse this decision, and avoid foreclosing on veterans who simply wish to keep paying their mortgage and keep their home.”
Rep. Mark Takano, HVAC Ranking Member
Put a figure on the exposure the same month: “With the sudden shutdown of the VASP program, as many as 80,000 veterans and military families have been stripped of a vital assistance program established to prevent the tragedy of foreclosure.”
Apr 30, 2025
CNN
Reported VASP cancelled on roughly eight days’ notice with about 75,000 borrowers three or more payments behind and only ~17,000 accepted.
Jul 2025
DLS Servicing
An executive whose firm works with 59 servicers began warning clients of rising FHA and VA foreclosures, a year before the mid-year data confirmed it.
Senate and House VA Committee leaders, on passage.
When Congress passed the replacement authority, its committee leaders described what it was for, in a bipartisan and bicameral statement: the legislation “will assist veterans who are facing financial hardships and provide VA with a tool to better help veterans stay in their homes and avoid foreclosure.” It was signed into law on July 30, 2025. The final policy implementing it was published June 1, 2026 and submissions opened June 15, 2026, and families were foreclosed on across that interval.
Mar 12, 2026
MBA & CHLA
Told VA in comment letters that its draft would leave veterans “substantially worse” off than Fannie, Freddie or FHA borrowers, and asked for at least 180 days to implement.
Apr 2, 2026
NPR
Published its investigation into VA foreclosures and the collapse of the rescue path.
May 2, 2026
Newsweek
Reported veterans facing a housing squeeze as VA relief ended and replacement housing plans stalled.
May 14, 2026
Mortgage Bankers Association
Quarterly survey put VA delinquency at 4.99% against 2.75% conventional, the stress already visible in the data.
May 20, 2026
Sen. Blumenthal
Told the Senate Veterans’ Affairs Committee that more than 15,000 veteran families had already been foreclosed on.
Jun 5, 2026
American Bankers Association
Called the final policy a real improvement over the draft, while noting several technical issues still requiring clarity from VA
Jun 23, 2026
Local broadcast press
Covered the surge and told veterans to contact their servicers early, guidance that only works if the servicer has implemented the program.
The outcome was named in advance, repeatedly, by the people best positioned to see it. The gap was left open anyway. (C027).