Announcement 20-0020: IRS 4506T Services Temporarily Suspended

Overview

The IRS has announced a temporary suspension of their Income Verification Express Service (IVES) due to their COVID-19 procedures.  IVES is used by mortgage vendors to obtain IRS transcripts.  It appears that orders placed on and prior to March 26, 2020 will continue to be processed by the IRS, albeit with significant delays, and it is unclear when orders placed on and after March 27, 2020 will be processed.

During this time, Carrington Mortgage Services, LLC (CMS) will follow our Government shutdown policy for all loan products with the exception of Non-Agency.

Internal Revenue Service (IRS)

In the event a shutdown impacts the IRS issuing tax return transcripts the following guidance is applicable:

• The Underwriter must condition for the processed 4506T tax transcripts in order to close the loan
• All loans with income discrepancies must be resolves prior to delivery
• Completed and 4506T forms are required at closing

Refer to the product specific underwriting guidelines for detailed requirements.

Operational Requirements:

• If product specific guidelines require processed 4506T tax transcripts or upon Underwriter discretion, condition as PTP.
• Non-Agency will require processed 4506T tax transcripts PTD.
• Account Managers and Loan Processors will continue to order the transcripts when the condition is placed on the approval.

As a reminder, CMS has the following policies related to IRS transcripts:

Non-Agency

As a reminder, CMS is not currently accepting new submissions or locks of non-agency loans.

For existing locked loans, the following products require verification of all full doc and 1-year alt doc income types using IRS transcripts:

• Carrington Flexible Advantage
• Carrington Flexible Advantage Plus
• Carrington Prime Advantage

IRS transcripts are not required for Carrington Investor Advantage and borrowers qualified using 12- or 24-months bank statements.

FHA, VA, Fannie Mae & Freddie Mac

CMS does not require IRS transcripts to validate income for FHA, VA, Fannie Mae, or Freddie Mac loans.

Underwriters may request IRS transcripts under circumstances such verifying recently-filed tax returns used for qualifying, the filing of amended tax returns, or when inconsistencies are revealed with income documentation during the underwriting process.  The following may be used as alternatives:

To evidence 2019 returns are filed:

• Attempt obtaining a refund status printout from https://sa.www4.irs.gov/irfof/lang/en/irfofgetstatus.jsp for borrowers receiving an income tax refund
• Obtain alternate proof of filing (such as an e-file receipt, stamped return, letter from CPA, etc.) along with proof of payment of taxes or updated installment agreement for borrowers with tax liability
• Have the borrower provide transcripts using the IRS information and links below

To verify amended returns:

• Obtain a stamped 1040X and verify payment of additional taxes owed, if any
• Have the borrower provide transcripts using the IRS information and links below
• As a reminder, tax returns may not be amended for qualifying purposes

When inconsistencies are revealed during the underwriting process, Underwriting Supervisors and Managers will continue to use the “Request Suspicious Activity Review” function in Encompass so that QC may review on a case-by-case basis.

Resources

The following resources and FAQ provided by the IRS may be helpful for borrowers when borrower-provided transcripts are requested to verify current tax return and amended tax return filings: https://www.irs.gov/individuals/get-transcript-faqs

Q9. How long must I wait before a transcript is available for my current year tax return?

If you filed your tax return electronically, IRS's return processing takes from 2 to 4 weeks before a transcript becomes available. If you mailed your tax return, it takes about 6 weeks. If you didn’t pay all the tax you owe, your transcript may not be available until mid-May or a week after you pay the full amount owed. Refer to transcript availability for more information. 

Once your transcript is available, you may use Get Transcript Online, you may order a tax return transcript and/or a tax account transcript using Get Transcript by Mail or call 800-908-9946. Please allow 5 to 10 calendar days for delivery. You may also request any transcript type listed below by faxing/mailing Form 4506-T, Request for Transcript of Tax Return as instructed on the form. The time frame for delivery is the same for all available tax years.

Contacts

Please contact CorrespondentRM@carringtonms.com with any questions.

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