Guidance may come before regulations for loans already in default
What the document says“With respect to a loan described in paragraph (2), the Secretary may-- ``(A) before prescribing regulations, issue administrative guidance regarding the making of a partial claim relating to such loan; and ``(B) establish, through such guidance, additional requirements applicable to such a partial claim.”
For a loan the Secretary of Veterans Affairs determines was in default on the day the new section was enacted, the Secretary may issue administrative guidance before writing regulations, and may set extra requirements through that guidance.
What the document actually says“With respect to a loan described in paragraph (2), the Secretary may-- ``(A) before prescribing regulations, issue administrative guidance regarding the making of a partial claim relating to such loan; and ``(B) establish, through such guidance, additional requirements applicable to such a partial claim.”
For some loans the VA can put out short notes first. It can add extra rules in them.
Writing full rules takes a long time. These loans were already behind on the day the law passed.
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