CURRENT STATUS · FACTUAL REVIEW SEPTEMBER 18, 2026
VA launched the Partial Claim in June. That does not mean every servicer has implemented it.
VA can accept Partial Claim trial-plan events. Servicers were given until November 28, 2026 to implement the new Loss Mitigation Waterfall and the Partial Claim. At least one large servicer has publicly announced implementation. Families already foreclosed on, displaced, or outside the handbook's eligibility barriers remain a separate unresolved cohort.
VA policy
June 1
Final handbook policy issued.
VA acceptance
June 15
VA began accepting Partial Claim trial-payment-plan events.
Servicer implementation
Your servicer
Verify now: ask your servicer, in writing, whether it is implemented for your loan.
Deadline
November 28
VA's implementation deadline for servicers, 2026.
THE FOUR ANSWERS
What is live, what varies by servicer, what the deadline is, and what is still unknown
Four questions, answered in the order a family needs them.
What is live now?
VA formally launched the Partial Claim Program on June 15, 2026, and VA systems can accept Partial Claim trial-payment-plan events.
What varies by servicer?
Borrower access depends on the mortgage servicer having implemented both the new Loss Mitigation Waterfall and the Partial Claim. VA says the two must be implemented together.
What is the implementation deadline?
VA gave servicers 180 days from its June 1 final policy to implement the program. VA's borrower guidance gives November 28, 2026 as the deadline for servicers to add Partial Claims to their systems.
SOURCE REGISTRATION HOLD · VA's borrower foreclosure guidance on VA.gov, which carries the November 28 date for borrowers, has no row in the source register yet. The date itself is also carried by S006.
What remains unknown?
VFC has not located a comprehensive public VA list showing implementation status for every mortgage servicer.
That is a search finding, not proof that no such record exists.
VA can accept the new Partial Claim. A borrower can receive one only after their servicer has implemented the new Waterfall and Partial Claim process.
"Launched is not available." A program can be live at the Department and still be out of reach for a family whose servicer has not yet implemented it.
WHERE IS THE IMPLEMENTATION DATA
VFC has not located a comprehensive public VA servicer-by-servicer implementation list
A veteran cannot work out their own servicer's operational status from VA's June launch announcement alone.
Question to search finding
The question
Does VA publish a complete servicer-by-servicer implementation list?
What the search returned
VFC did not locate a comprehensive public VA servicer-by-servicer Partial Claim implementation list in the sources below.
Does VA publish a complete servicer-by-servicer implementation list?
Searched, not located
Where we searched
VA's Partial Claim servicer FAQ; borrower foreclosure guidance; June 15 launch release; VALERI Technology Knowledge Center; Servicer Newsflashes; VALERI guides and templates; Partial Claim training resources; and servicing circulars.
Last checked
September 18, 2026
What would resolve it
A VA-published cross-servicer status record, or verified implementation evidence for individual servicers.
This describes our search, not the world. We looked in the places named above and did not find it. That is not evidence that the record does not exist - it may exist somewhere we have not searched, may not be published, or may be held in a form we cannot reach.
This is a search finding, not proof that no such record exists.
Registered sources in that scope: S025 servicer FAQ · S007 launch release · S292 VALERI release notes. SOURCE REGISTRATION HOLD: VA.gov borrower foreclosure guidance, Partial Claim training resources, and the servicing circular archive page have no row in the source register yet.
SERVICER IMPLEMENTATION TRACKER
Which servicers have implemented the new Partial Claim
This is the shell and its state grammar. No rows are published yet.
The five states, in words
Implemented, verified
VFC located primary evidence that this servicer has implemented the new VA waterfall and Partial Claim.
Implementation announced
The servicer has publicly stated it implemented. That is the servicer’s own position; VFC has not independently verified operation for any particular loan.
Partial or unclear
Evidence is mixed, incomplete, or covers only part of the program.
No public notice located
VFC did not find a public notice in the sources it searched. This is a statement about our search. It does NOT mean the servicer has not implemented, and it must never be read that way. Every row in this state carries a last-checked date, the search scope, and a limitation.
Needs review
Flagged for re-checking, typically because the evidence is dated or a source changed.
Servicer implementation status. Columns fixed; no rows published as of 2026-09-17.
Servicer
Verified status
Announcement / effective date
What the servicer said
What VFC verified
Primary evidence
Last checked
Limitation
No rows published. See the note below the table.
No rows published. There is no approved structured servicer dataset yet, and this pass did not research one. Rows will be added only from verified evidence, one servicer at a time, each carrying its own source, last-checked date and limitation.
An empty tracker is the honest current state of the record. It is not a claim that no servicer has implemented.
WHO CONTROLS WHAT DURING ROLLOUT
VA sets the program and the deadline; the servicer decides whether a loan can reach it
Two different actors, two different records, two different things a family can ask for.
PROGRAM LEVEL
VA
Program policy
The implementation deadline and window
VALERI system capability
Program-wide servicing guidance
Borrower-facing guidance
LOAN LEVEL
Your mortgage servicer
Internal implementation
Borrower review
The status of a specific loan
Trial payment plan and loss-mitigation communications
Its own implementation notices
Policy is not the same as regulation. VA is operating the program through final agency policy and handbook guidance while separate rulemaking remains unfinished. VA published its final policy June 1, 2026 and launched the Partial Claim Program June 15. As of September 18, the separate rulemaking, RIN 2900-AS78, remains listed at the Proposed Rule Stage.
VA continued releasing Partial Claim implementation infrastructure after launch. VALERI releases in June, July and September added or refined event submission, processing, tracking and audit functionality, and VA revised servicer templates during the rollout.
SELECTED CHRONOLOGY
How the program reached the state it is in now
Selected milestones only. The full dated record is on The Record.
Jun 1, 2026
Final handbook policy issued
The VA published the Partial Claim rules (M26-4 Ch. 22).
done
Jun 15, 2026
VA accepts submissions
VA began accepting Partial Claim trial-payment-plan events.
done
Your servicer
Has your servicer implemented it?
Ask your servicer whether the new VA waterfall and Partial Claim are implemented for your loan. All servicers face the November 28 deadline.
verify now
Text description: VA published final M26-4 handbook policy June 1 and began accepting trial-plan events June 15. During the rollout, verify implementation with your own servicer. VA requires implementation by November 28, 2026.
The gates Congress never wrote
The law opened the door. The VA added locks Congress never wrote, and can remove without a new law. Three VA-added barriers (Manual M26-4, Ch. 22):
Active-default requirement, bars families already foreclosed on.
Why these barriers exist and why they are reversible: Policy & Fiscal → The Secretary's Section 3(h) emergency authority for pre-enactment defaults remains unused a year after enactment.
Nobody was carried over when the first program ended
Families who called to resume paying were told to pay the arrears up front instead. Families in COVID-19 forbearance were told, in guidance issued to their servicers, that paused payments would be repaid over time and that a lump sum would not be required. When the COVID-19 partial claim expired by regulation on October 28, 2022, the families already enrolled were not carried into any successor option. There was no grandfathering provision and no notice to borrowers that the terms had changed.
86 FR 28708 set the COVID partial claim at zero percent interest with no monthly repayment to VA and the balance due at end of loan.
COMMUNITY-REPORTED
VFC has received reports from cohort families that they were quoted five-figure cure amounts when trying to resume payments.
WHO IS STILL NOT SOLVED BY THE CURRENT PROGRAM
PROJECT ANALYSIS
Not one group, three, each owed a different fix
This project's analysis finds three groups of families, each harmed by a different government action, and no single program that reaches all three.
"They just stopped paying" collapses three distinct groups into one false story. Each was harmed by a different government action, and each needs a different remedy. No single program reaches all three, which is why the VA can call the crisis "handled" while most families stay trapped.
COHORT A
The forbearance families
Who
Families who did exactly what the government said and paused payments under COVID forbearance.
What changed
The same-rate exit disappeared when the COVID partial claim ended in October 2022. Pushed toward balloon payments or unaffordable modifications.
The fix they need
A restored same-rate modification or partial claim, applied to families already forced into higher-rate deals.
COHORT B · THE VASP GAP
Foreclosed in the coverage gap
Who
Families who fell into default after the VA killed VASP (May 2025) and before the Partial Claim launched (June 2026), a year with nothing operational to help.
Unresolved
Many are already foreclosed on or displaced.
The fix they need
The unused Section 3(h) authority, applied to pre-enactment defaults, plus counting and rehousing the displaced.
COHORT C
Eligible on paper, barred in practice
Who
Families who may qualify under the new rules but are blocked by VA-added eligibility criteria, or are still waiting for their servicer to complete implementation during the rollout window.
The fix they need
Remove the administrative barriers, and pause foreclosures and evictions until the program is operational at every servicer.
The through-line: every one of these harms began with a government action, and every one is reversible by government action. See the legal basis for each fix in Policy & Fiscal Analysis.
PROJECT ANALYSIS
The count does not fall, because it replenishes.
New families enter foreclosure as fast as others are pushed out of it, so a flat number across months is not a stable population. It is a queue with a door at each end.
No Partial Claim mechanism located that reopens a completed foreclosure
As of September 18, 2026, VFC did not locate in the reviewed VA Partial Claim and servicing materials a Partial Claim mechanism that reopens a completed foreclosure or applies the new Partial Claim retroactively to a loan already terminated by foreclosure sale.
The harm counts for families already affected are set out with their sources and dates in Harm counts.
Losing the house is the first domino, not the last
After foreclosure comes credit damage, automatic rental denials and, for some families, homelessness. What actually works, when it exists: direct case management and a warm handoff to a landlord willing to look past an automated screen. Families who found housing found it that way, almost without exception.
Foreclosure.
The house is lost, the first domino, not the last.
Retroactive credit damage.
Foreclosure hits credit backdated to the start of the government-directed forbearance, wiping out years of standing in one entry.
Auto-declined by screening software.
Landlord screening software reads that credit and auto-declines applications before a human ever sees them.
Over-income for aid, locked out of housing.
Disability income above poverty thresholds is over-income for the deepest assistance, while credit damage locks families out of market rents now quoted at $2,000+ against a former $1,400 mortgage.
Homelessness.
Cars, storage units, hotel vouchers that run out, family floors in other states. The exact population stable housing is known to protect.
Community-reported sequence, drawn from cohort families. Fuller housing analysis: Housing & Health →
THE NOTICE LEDGER, WHO WAS TOLD AND WHEN
They were told, on these dates, in these venues
Not a claim about what anyone knew. A record of what they were told, spanning two administrations.
DateWarning or requestWho told whom, and whereRecord status
March 2020
CARES Act forbearance begins. Paused payments are repaid over time and a lump sum is not required.
Notice: Federal agencies (interagency) told Servicers at CARES forbearance fact sheet.
DOCUMENTED FACTS049
Feb 15, 2024
The partial claim gap and foreclosure exposure are raised directly, three months before VASP launches.
Notice: Witnesses at hearing told House VA Committee at HVAC printed hearing record.
VA states it is ready for servicers to submit trial payment plans for modifications and partial claims.
Notice: VA told Servicers at VA announcement.
DOCUMENTED FACT
Nov 28, 2026
Deadline for servicers to update systems to deliver the partial claim.
Notice: VA told Servicers at VA handbook and email.
DOCUMENTED FACT
T006 (Dec 12, 2024) is kept here for historical review and is not presented as documented fact. Its source is pending: the MBA white paper it describes has not been located. A Dec 12, 2024 MBA publication found during verification concerns Ginnie Mae early-buyout securitization and issuer liquidity, and is not the source for this entry.
Eight dated entries used to sit in this ledger that are not notice. This page records who warned a decision-maker in advance of the harm. The eight below are the Department acting, the press reporting afterwards, and asks made after the fact. Each one is still on the site in full, with its source, on the page whose job it is.
The statutes and the handbook. Nov 12, 2025, 38 U.S.C. 3737 narrowed by Pub. L. 119-37 · Jun 1, 2026, VA's final partial claim policy, M26-4 Chapters 5 and 22 · Policy and cost
Asks and commitments still outstanding. May 20, 2026, the VA Chief Financial Officer at the Senate Veterans' Affairs Committee · May 26, 2026, the twenty-eight-member moratorium demand · Who is engaged, and where it stands
Press and program events. Apr 2, 2026, NPR on the rescue-program decision · Jun 15, 2026, the NCLC launch-day release · Jun 19, 2026, Military.com on equity-stripping risk · The dated record
These entries are set in the page. The full chronology, with every dated entry and its source, is on The Record.
NOT OUR CHARACTERIZATION
Two independent organizations identified the same gap within days of launch.
The National Consumer Law Center called for a pause on foreclosures until the new program is accessible, June 2026. Military.com reported the same implementation gap, June 19, 2026.
Secondary corroboration. It does not substitute for VA authority.
WHAT WE STILL DO NOT KNOW
The questions this page cannot yet answer
Each one shows its status and what would resolve it. An absence is recorded as an absence, never as a fact.
Which servicers are operational today?
Open
Last checked
2026-09-15
What would resolve it
Per-servicer primary evidence of implementation, or a complete VA list.
Until this is answered, no family can infer their servicer's status from VA's launch date.
What is the current number of VA borrowers in foreclosure?
Searched, not located
Where we searched
VFC's own review of public VA series. The page's existing wording records the outcome: VFC has not located a current VA public series showing foreclosures and displacement as they occur. The scope of that review is not itself documented in a canonical source.
Last checked
2026-09-15
What would resolve it
A current, dated VA public series showing foreclosures and displacement as they occur.
This describes our search, not the world. We looked in the places named above and did not find it. That is not evidence that the record does not exist - it may exist somewhere we have not searched, may not be published, or may be held in a form we cannot reach.
The latest verified counts are from spring 2026 and are shown with their original dates in Harm counts.
How many veterans became homeless after losing a VA-guaranteed home to foreclosure?
Searched, not located
Where we searched
The reviewed VA Home Loan and VA Homeless Programs materials, including VA's point-in-time count and SSVF and HMIS data resources.
Last checked
September 18, 2026
What would resolve it
A public data series linking VA-guaranteed home foreclosures to later veteran homelessness.
This describes our search, not the world. We looked in the places named above and did not find it. That is not evidence that the record does not exist - it may exist somewhere we have not searched, may not be published, or may be held in a form we cannot reach.
VA publishes broader veteran-homelessness and homelessness-prevention data. This finding concerns the absence of a publicly located foreclosure-to-homelessness measure, not the absence of homelessness data generally.
Is there a Partial Claim mechanism for loans already terminated by foreclosure sale?
Searched, not located
Where we searched
The reviewed VA Partial Claim and servicing materials: the Partial Claim servicer FAQs, the M26-4 final policy, and the June 15 launch release.
Last checked
September 18, 2026
What would resolve it
A VA mechanism that reopens a completed foreclosure or applies the Partial Claim retroactively, or a VA statement that none exists.
This describes our search, not the world. We looked in the places named above and did not find it. That is not evidence that the record does not exist - it may exist somewhere we have not searched, may not be published, or may be held in a form we cannot reach.
This is a finding about the Partial Claim and servicing materials reviewed. It does not establish that no other legal, administrative, property-disposition, or case-specific remedy could exist.
HARM COUNTS AND THEIR LIMITS
The latest counts VFC has verified, with the dates they were measured
These are spring 2026 figures. The September implementation update did not refresh them.
Most eligible families never had a path in, and they could not apply for themselves
Most families who were behind when VA cancelled Veterans Affairs Servicing Purchase (VASP) had not been accepted, and only their mortgage company (the loan servicer) could apply for them.
Behind at cancellation
75,000
veteran borrowers were three or more payments behind when VASP was cancelled.
NCLC and Center for Responsible Lending, May 1, 2025 · S124; also NPR and CNN
Accepted before shutoff
~17,000
had been accepted into the program before it was shut off.
Same sources
No path in
58,000+
had no path in, and only a servicer, never the veteran, could submit them.
Same sources
VFC method
All three figures are reported directly by the National Consumer Law Center and the Center for Responsible Lending, May 1, 2025: "As of April 1, there were 75,000 Veteran borrowers who had missed 3 or more payments"; "VA reported that 17,000 have been accepted for VASP"; and the termination "still leaves up to 58,000 or more Veterans and their families vulnerable to foreclosure." The 58,000 also equals 75,000 minus 17,000.
These figures are directly reported by the named source. Each is dated to when it was reported, not to today.
Stated at a Senate hearing
15,000+
At the May 20, 2026 Senate Veterans' Affairs Committee hearing, Sen. Richard Blumenthal said recent data indicated that more than 15,000 veterans had lost their homes since VASP ended.
SVAC hearing, May 20, 2026 · S001
Reported April 2, 2026
~90,000
VA borrowers reported by NPR on April 2, 2026 as behind on their mortgages or in the foreclosure process, based on ICE Mortgage Technology data.
NPR, Apr 2, 2026, ICE Mortgage Technology data · S002
THE MISSING LINKED MEASURE
?
How many veterans became homeless after losing a VA-guaranteed home to foreclosure.
No public series located · last checked Sep 18, 2026
VFC method
NO UNDUPLICATED TOTAL ESTABLISHED. The available counts describe different populations, dates and stages of mortgage distress. VFC has not established how much those groups overlap, so they should not be added into a single total of families affected.
NCLC testified that about 35% of seriously delinquent VA loans were in active foreclosure as of the end of 2025, citing ICE Mortgage Monitor data.
VFC method
Applied to NCLC's own count of roughly 90,000 seriously delinquent VA borrowers, that rate works out to about 31,500 VA borrowers in active foreclosure. This is a VFC-derived estimate, not a figure NCLC stated. Both inputs come from the same NCLC written statement of March 26, 2026: "about 35% of seriously delinquent VA loans were in active foreclosure" (p. 2) and "the roughly 90,000 VA borrowers who are seriously delinquent on their loan today" (pp. 3 to 4). 35% × ~90,000 = ~31,500.
The market is turning while servicer access remains uneven
The gap between launch and implementation is not running against a calm market. Foreclosure activity rose through the first half of 2026, and the stress is concentrated in exactly the loans the partial claim is meant to protect.
Filings, H1 2026
227,548
U.S. properties with foreclosure filings, up 21% year over year and 28% above the first half of 2024.
ATTOM 2026 mid-year report · S028
VA delinquency, Q1
4.99%
Against 2.75% on conventional loans. FHA sits highest at 11.88%.
Quarterly survey data · S029
Modified rate
7.125%
Borrowers who defaulted at about 4% are being modified to roughly the market rate, close to double the payment.
Practitioner account, July 2026 · S030
A loss-mitigation executive whose firm works with 59 servicers told trade press in July that VA borrowers who defaulted on loans at about 4% are being modified to roughly 7.125%, "nearly double the payment", with no reduced-payment alternative available to them. She expects FHA and VA foreclosures could more than double by next autumn.
VA/FHA point-in-time comparison
FHA loans and VA loans are both pooled in Ginnie Mae securities, so the same monthly Ginnie Mae files report both. Through this period FHA kept a permanent partial claim and VA did not.
VA, June 2026
1.23%
946 foreclosures completed, against 76,814 loans 90 or more days behind
Ginnie Mae monthly liquidation files, removal reason 3 · S242
FHA, June 2026
0.42%
1,655 completed, against 398,945 loans 90 or more days behind
Same files, same month, same measure · S242
In the June 2026 Ginnie Mae files VFC analyzed, completed foreclosure removals relative to loans three or more months delinquent were 1.23% for VA loans and 0.42% for FHA loans, a ratio of 2.97.
DOCUMENTED FACTS242
VFC method
Re-derived 2026-09-02 from the Ginnie Mae monthly liquidation files rather than carried forward from an earlier working note. Removal reason 3 (foreclosure with claim payment), measured against loans 90 or more days delinquent, same month and same measure on both sides.
Foreclosure costs more than keeping the family housed. Against this project's estimate of $195,300+ per foreclosure, the full fiscal case finds $147M net savings versus the cost of foreclosure. Two paths and every line item live on Policy & Fiscal; every figure is source-linked on Evidence.
The standard answer is that veterans have a deep bench of housing help, roughly $3.2 to $3.5 billion a year for VA homeless programs, HUD-VASH vouchers, SSVF, and a homelessness rate cut by half since 2010. All of that is real. None of it prevents the foreclosure that puts these families on the street in the first place. Two things are true at once: the recovery system exists, and it is not reaching the people this crisis is creating. These are homelessness recovery programs; they start after a family has already lost its home.
PROJECT ANALYSIS
You cannot foreclose your way to fewer homeless veterans.
Keeping a family in the home it already has, through the partial claim or a targeted moratorium, is the upstream fix, and the cheaper one. The VA is generating the homelessness it then asks its overloaded programs to absorb. Any real remedy has to do two things at once: pause foreclosures and evictions until relief is genuinely available, and account for and rehouse the families already displaced, not refer them into a HUD-VASH queue the VA itself could not staff or track.
HUD-VASH starts too late, and misses most who qualify
It is a homeless-housing voucher, not foreclosure prevention; a family generally has to already be homeless to qualify. GAO found 174,045 eligible veterans went un-referred from 2020 to 2024, with no documented reason for 87%. Case-manager turnover runs 20–26% a year. Even with a voucher, veterans still cannot find available, affordable units.
SSVF is capped, time-limited, and rationed locally
The main prevention option is income-restricted at a 50% area-median-income base, runs in months not years, and is delivered through local grantees whose funds run out. When applicants outnumber resources, grantees prioritize and turn families away, and coverage varies community to community.
VA SSVF program guidance
Grant & Per Diem housing is not everywhere
Transitional housing runs through community organizations that must win competitive VA grants "as funding permits", so whether it exists near you depends on whether a local provider is funded. Bed capacity has long fallen short of need, and it is congregate transitional housing, not a home.
VA GPD program; 38 CFR Part 61
The gap nobody names. There is also no dedicated national legal pipeline for veterans in foreclosure. Most veteran legal aid covers disability, healthcare, and discharge issues. Families facing foreclosure or eviction are routed to consumer and housing legal help that was never built for them. The shortfall predates this crisis: in the Legal Services Corporation's own survey, low-income households with veterans or military personnel received inadequate or no professional legal help for an estimated 88% of their civil legal problems.
State by state, the veteran families who have connected with this project, shown as a count only, never named, unless a family gives written consent. We add states as families reach us; this is a floor, not a ceiling.
Primary source documents are shown as captured screenshots with their capture date. VFC summaries and analysis are labelled PROJECT ANALYSIS and are visually distinct from them.
CORRECTIONS AND PROVENANCE
How this page is maintained, and how to correct it
Page last updated: 2026-09-18 (factual corrections and layout). Implementation status last updated: 2026-09-15. Harm counts: spring 2026, not refreshed since.
