I have several files that I’m trying to submit to USDA RD for determination so that we can turn in our 523 grant application. I have been trying to get several past VOEs; some I have faxed several times, mailed, contacted the employer and even hand delivered. They are not completing them for us and are delaying submission of the applications. These are the last items needed to submit and I have been trying to get them for two to three weeks in some cases. What should I do?
Unable to Verify
Dear Unable to Verify,
First, the preferred source is always documentation that is readily available from the applicant, such as award letters, pay stubs, W-2s and tax returns because this is the quickest way to obtain the information and reduces processing delays.
When the preferred source isn’t readily available, then we move to using forms. HB-1-3550, 4.3 E reads: “Written verifications provided by third-party sources or documents prepared by third-party sources are required when the applicant is unable to provide sufficient recent, reliable and consistent documentation.” That means that when you have the readily available documents, and they align with what was reported on the application, then you use them. RD then completes an oral verification to confirm additional information.
If a third party verification is needed, HB-1-3550, 3.15 indicates that “an applicant should not be penalized if a respondent refuses to provide the requested information. If the respondent does not respond to the verification form after 14 days and does not respond to a follow up call, the loan Originator should move to the use of alternative methods of verifying the information.”
Based on what you have reported, I think you may not need the VOE at all (if the tax returns/W-2s support the prior employment income as listed on the application). But in the event that you do need the VOE – if you sent it, didn’t have a response, called the employer and still no response – then I would document that in the Loan Narrative.
Hopefully the need for obtaining VOE is very minimal. Most applicants likely have other documentation that can be used to avoid the need for a VOE.
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