A refinance with built-in guardrails
Quick answer: A VA IRRRL — Interest Rate Reduction Refinance Loan (the VA streamline refinance) — swaps your existing VA loan for a new VA loan at a lower rate, with no cash out. In most files, there is no VA-required appraisal either. It's worth doing when your numbers clear VA's own three tests — seasoning, 36-month fee recoupment, and a real rate reduction. Indeed, Congress built those tests to make sure the refinance profits you, not a loan salesman.
The VA IRRRL is the rare mortgage where the law does your skepticism for you. A wave of serial-refinance churning cost veterans real money in the 2010s. In response, Congress wrote three borrower protections directly into federal law. The protections: a seasoning clock, a 36-month cost-recoupment fence, and a minimum rate drop. So the modern streamline is fast because it's fenced. If your deal clears the tests, it closes with less friction than any other refinance in the mortgage business. In contrast, if it can't clear them, VA won't back it, which is the system working exactly as designed. This guide walks 38 U.S.C. §3709 in plain English. It runs the recoupment math on two honest examples (one passes, one fails). It also covers the 0.5% funding fee, the occupancy rule most people get backwards. Finally, it flags when the bigger when-to-refinance question should be answered "not yet."
Key takeaways
- VA-to-VA only, no cash out. An IRRRL replaces an existing VA-backed loan; the new balance is essentially the payoff plus allowable costs and up to 2 discount points. Equity access means VA's separate cash-out refinance instead.
- Seasoning protects you first. Per 38 U.S.C. §3709(c), the new loan can't be VA-backed until the later of two milestones. Those are six consecutive monthly payments made, and 210 days after your first payment due date.
- Recoupment is the worth-it test. Fees and costs must be scheduled to be recouped within 36 months through the lower payment (§3709(a)). The statute excludes taxes, escrow, and the VA funding fee from that math. Our illustrative example: $4,000 ÷ $120.17/mo = 33.3 months — a pass.
- The rate drop has statutory floors. Fixed-to-fixed needs at least 0.5 percentage point (50 basis points); fixed-to-ARM needs at least 2 points (200 basis points) (§3709(b)). ARM-to-fixed can qualify on stability grounds under 38 CFR 36.4307.
- The funding fee is 0.5% — financeable, identical on every use. Disability-compensation recipients, DIC surviving spouses, qualifying pre-discharge ratings, and active-duty Purple Heart recipients pay none of it.
What is a VA IRRRL — and what can't it do?
An Interest Rate Reduction Refinance Loan — IRRRL, usually said "earl" — replaces one VA-backed loan with another. Typically, the point is a lower rate and monthly payment. Most people simply call it the VA streamline refinance. It can also trade an adjustable rate for a fixed one. Per VA's own eligibility rules, three things must all be true. You already have a VA-backed home loan, and you're using the IRRRL to refinance that same loan. Finally, you can certify that you currently live in — or once lived in — the home it covers. That last clause matters more than it looks, and we'll come back to it below.
What an IRRRL cannot do
Just as important is what an IRRRL is not. It is VA-to-VA only — a conventional or FHA loan can't be streamlined into the VA program this way. And it is not a cash-out vehicle. Under 38 CFR 36.4307, the new loan amount essentially can't exceed the old loan's payoff balance. The only additions allowed are closing costs and up to a 2% discount. Want to pull equity out, or move a non-VA loan into the VA program? The right tool is VA's cash-out refinance — our full guide to what a cash-out allows and costs in Nevada covers it end to end. That is a separate loan type with full underwriting, an appraisal, and a higher funding fee. The table below compares them side by side.
Closing costs still exist on a streamline, but you have options for paying them. Per VA, the costs can be financed into the new loan. Alternatively, the lender can price the loan at a slightly higher rate and pay costs on your behalf. Both routes have arithmetic consequences — and the arithmetic is exactly what the law now forces everyone to show you.
Is a VA streamline refinance the same thing as an IRRRL?
Yes. A VA streamline refinance and a VA IRRRL are one loan with two names. Federal law names it the interest rate reduction refinancing loan (38 U.S.C. 3729(b)(4)(F); 38 CFR 36.4307). VA's program pages shorten that to Interest Rate Reduction Refinance Loan. The three tests themselves live in 38 U.S.C. §3709. "Streamline" is the everyday name. It comes from the light process: in most files, no VA-required appraisal and no full re-underwriting. Some lenders also say VA-to-VA refinance. That third name points at the requirement that never bends. An existing VA-backed loan is the only loan an IRRRL can replace.
The naming matters for a practical reason. Refinance mailers prefer the friendlier name. So a borrower can reasonably ask whether a VA streamline refinance (the IRRRL) follows looser rules than the statute describes. It does not. Whatever the envelope calls it, the same three protections apply. Those are the 210-day seasoning clock, the 36-month recoupment fence, and the net tangible benefit floors. In short, ask by either name. The tests that follow are identical.
One caution: the FHA streamline refinance is a different program with a similar nickname. It refinances FHA-backed loans under HUD's rules, not VA's. Therefore, nothing in this guide applies to an FHA-backed loan, and an FHA loan cannot use the IRRRL.
Why does the law slow your refinance down? The three protections
The law that ended the churn
In the mid-2010s, some lenders discovered that veterans could be refinanced over and over. Each refinance generated fees and restarted the loan clock. Meanwhile, the "savings" never caught up with the costs. Regulators call the practice churning. Congress responded with the Protecting Veterans from Predatory Lending Act, enacted May 24, 2018 as part of Public Law 115-174. That act created 38 U.S.C. §3709. Then a 2019 amendment (Public Law 116-33, July 25, 2019) tightened the seasoning clock further. The result is three statutory tests that every IRRRL must pass before VA will back it:
The three protections at a glance
| Test | What the law requires | Where it lives |
|---|---|---|
| Loan seasoning | The new loan can't be VA-backed until the later of: the date you've made at least six consecutive monthly payments on the loan being refinanced, and the date that is 210 days after the first payment due date of that loan | §3709(c) |
| Fee recoupment | All fees, closing costs, and expenses — excluding taxes, amounts held in escrow, and the VA funding fee — must be scheduled to be recouped within 36 months of loan issuance, through the lower regular monthly payment; the lender must certify the recoupment period to VA | §3709(a) |
| Net tangible benefit | The lender must give you a net tangible benefit test. Fixed-rate into fixed-rate: new rate at least 50 basis points (0.5 percentage point) lower. Fixed-rate into adjustable-rate: at least 200 basis points (2 percentage points) lower. Either way, strict limits apply to producing the drop through discount points | §3709(b) |
Notice what the statute is doing: it never tells you a streamline is a good idea. Instead, it forces every deal to prove it can't be a bad one in the ways that hurt veterans before. The proof takes three forms: a clock, a break-even certification, and a rate floor. VA itself adds a plain-language warning on its refinance pages. Claims that you can "skip payments" or get very low interest rates are, in VA's words, signs of a misleading offer. If a mailer sounds like free money, the statute below is the reason it probably isn't.
Seasoning: the 210-day and six-payment clock
Seasoning answers the "how soon" question with a date you can compute. Under §3709(c), an IRRRL can't be VA-backed until the later of two milestones on the loan being refinanced. First, you've made at least six consecutive monthly payments. Second, 210 days have passed since the first payment due date. Both prongs run from the old loan. The 2019 amendment pegged the 210 days to the first payment due date — not the date you happened to pay. As a result, the clock is objective.
Here is how the two prongs interact in practice. Suppose your first payment was due May 1, 2026 and you pay on schedule every month. Your sixth consecutive payment lands October 1, 2026. But 210 days from May 1 is November 27, 2026, and the statute takes the later date. So in a typical on-time file, the 210-day prong controls. The realistic earliest window for a new IRRRL opens roughly seven months after your first payment comes due. If you've ever wondered why nobody can legitimately streamline your brand-new loan in month three, this is why. Any pitch that says otherwise is pitching around federal law.
Net tangible benefit: how far does your rate have to fall?
The second protection is a floor under the word "reduction." Per §3709(b), the lender must provide a net tangible benefit test, and the statute then sets exact thresholds by loan type. Going fixed-rate to fixed-rate, the new rate must be at least 50 basis points — half a percentage point — below the old one. Going fixed-rate to an adjustable-rate loan, the gap widens to at least 200 basis points, or two full percentage points. That is because trading away rate certainty demands a much deeper discount.
The statute also closes the discount-point loophole. The lower rate can't be produced solely by paying discount points. The exception: points paid at closing and not rolled into the loan balance. However, if points are financed anyway, the law caps leverage. With one point or less, the resulting loan can't exceed 100% loan-to-value. With more than one point, it can't exceed 90% loan-to-value. In other words, you can't be sold a "lower rate" that is really just your own equity, prepaid.
One direction the statute's spreads don't govern: moving from a VA adjustable-rate loan to a fixed rate. VA's regulation, 38 CFR 36.4307, allows an IRRRL where the new loan is a fixed-rate loan refinancing a VA ARM. Here, the benefit is stability rather than spread. That sits alongside its baseline options of a lower principal-and-interest payment or a shorter term. So an ARM-to-fixed streamline can make sense even when the fixed rate isn't dramatically lower. However, the recoupment fence in the next section still applies, and it's the one that decides "worth it."
Is the VA IRRRL worth it? The recoupment math, worked
Here is the protection that answers the money question directly, because it is the money question. Under §3709(a), your lender must certify the recoupment period to VA for the refinance's fees, closing costs, and expenses. Taxes, amounts held in escrow, and the VA funding fee are excluded. Moreover, the schedule must recoup every remaining cost within 36 months of loan issuance, through the lower regular monthly payment. The formula is the same one VA's own IRRRL page tells every borrower to run. Divide your closing costs by your monthly savings, then look hard at the answer.
"All of the fees and incurred costs must be scheduled to be recouped on or before the date that is 36 months after the date of loan issuance; and ... The recoupment must be calculated through lower regular monthly payments (other than taxes, amounts held in escrow, and fees paid under 38 U.S.C. chapter 37) as a result of the refinanced loan."38 CFR 36.4306(b)(1)(ii)-(iii), Code of Federal Regulations -- ecfr.gov
Say your current VA loan has a $245,000 balance on a 30-year fixed rate of 6.75%, and an IRRRL would replace it with a new 30-year fixed at 6.00% — a 0.75-point drop, comfortably clearing the 0.5-point fixed-to-fixed floor:
Current principal & interest: $1,589.07/mo · New principal & interest: $1,468.90/mo
Monthly savings: $1,589.07 − $1,468.90 = $120.17
Recoupable costs (excluding taxes, escrow, and the funding fee, per §3709(a)): $4,000
Recoupment: $4,000 ÷ $120.17 = 33.3 months → inside the 36-month fence — passes
Counting the funding fee anyway
The 0.5% funding fee on this loan would be about $1,225. The statute leaves it out of the certification — but your own worth-it math shouldn't, so count it. For example, even with the fee added, total costs of $5,225 recoup in about 43.5 months against $120.17/mo, and then the savings run for decades. Every figure here is an illustrative example, not a quote or an offer.
Now shrink the loan and the rate drop. A $160,000 balance at 6.50% refinanced to 6.00% technically clears the 0.5-point rate floor — but watch the recoupment:
Current principal & interest: $1,011.31/mo · New: $959.28/mo · Savings: $52.03
Recoupment on the same $4,000 in costs: $4,000 ÷ $52.03 = 76.9 months → more than double the fence — fails
When the fence says no
VA can't back this loan, and that refusal is the protection doing its job: at $52 a month, you'd spend six and a half years just breaking even. The honest fixes are structural — a materially lower rate, materially lower costs (lender credits), or simply keeping the loan you have. Passing the rate-drop test while failing recoupment is common on smaller balances, which is exactly why both tests exist.
Two practical notes belong here. First, financing your closing costs into the new balance is allowed, but it raises the payoff you're carrying. That stretches real-world break-even. Therefore, treat the 36-month fence as a ceiling, not a target. Second, your break-even is only half the decision. Whether this is the right time is the other half. Our guide to when refinancing actually makes sense covers that question for every loan type, not just VA.
Want your recoupment math run on real numbers?
Ten minutes with a Las Vegas loan officer: your balance, your rate, your actual costs — divided honestly, the way the statute requires. If the math says keep your loan, that's exactly what we'll tell you. No obligation.
Get your fast quoteWhat does the IRRRL funding fee cost — and who pays nothing?
Most VA loans carry a one-time funding fee that keeps the program running without down payments or monthly mortgage insurance. The funding fee on an IRRRL is 0.5% of the loan amount — the smallest percentage anywhere on VA's fee schedule. Congress sets that rate directly, in the loan fee table at 38 U.S.C. 3729(b)(2)(E). Per VA, it does not change based on your down payment history or whether you've used the benefit before. On the $245,000 example above, that's about $1,225, and you can finance it into the loan or pay it at closing.
Just as important, a large group of borrowers is exempt. Per VA's funding fee page, you pay no funding fee at all if any of these is true. You're receiving VA compensation for a service-connected disability. Likewise, you're eligible for that compensation but receiving retirement or active-duty pay instead. You're receiving Dependency and Indemnity Compensation (DIC) as a surviving spouse. Similarly, you hold a qualifying proposed or memorandum pre-discharge rating. Finally, you're an active-duty service member who received the Purple Heart, with evidence provided on or before closing. And if you're awarded compensation later with an effective date before your closing, a refund may be available. The full schedule, the exemption details, and how financing the fee changes your math are in our VA funding fee guide. To run the number for your own loan amount, use the VA funding fee chart and calculator.
Occupancy, appraisal, and what lenders still check
The IRRRL occupancy rule runs opposite to most people's instincts. A VA purchase loan requires you to intend to occupy the home. An IRRRL only asks you to certify you currently live in the home or previously occupied it as your home. That standard comes from VA's eligibility rules and 38 CFR 36.4307. Take the Las Vegas house you bought at your last duty station and kept as a rental after a PCS move. It can usually still be streamlined, because prior occupancy counts. The regulation even lets a spouse's occupancy carry the certification in certain active-duty situations. If you're unsure whether your original loan and service record line up, start with our VA loan eligibility guide. Moreover, the same Certificate of Eligibility that opened your first loan shows the prior use of your entitlement. Your lender can pull it electronically.
On documentation, precision matters, so here is the honest version. VA generally does not require a new appraisal or a full credit-and-income underwriting package for an IRRRL. That's the streamline part, and it's why these files can close quickly. Lenders, however, are allowed their own requirements, known as overlays. For example: a mortgage-payment-history review, a credit pull, sometimes an appraisal, and always identity and occupancy certification. Nobody reputable offers a "no-document" loan, and a second mortgage on the home adds one more step. Per VA, that lienholder must agree to stay behind the new first mortgage. Want a plain-English tour of what a file actually gets checked for? Our guide to what underwriters check walks the whole list. The IRRRL simply shrinks it.
Property condition is the other place a purchase or cash-out file parts ways with a streamline. Those loans can call for a wood-destroying insect report and the rules vary by state, so our VA termite inspection requirements by state guide walks through who orders it and who pays.
IRRRL vs. VA cash-out refinance: which one fits?
The two VA refinances solve different problems, and choosing between them is usually quick once you see them side by side:
| Feature | IRRRL (streamline) | VA cash-out refinance |
|---|---|---|
| What it replaces | An existing VA-backed loan only | A VA or non-VA loan |
| Cash out of equity | No — payoff plus allowable costs only | Yes, within VA and lender limits |
| Occupancy | Certify you live in the home or previously did | You'll live in the home you're refinancing |
| Appraisal & underwriting | Typically not VA-required; lender overlays possible | Full appraisal plus credit and income underwriting |
| §3709 tests | Seasoning, 36-month recoupment, and net-tangible-benefit floors all apply | Exempt from §3709(a)–(c) by §3709(d); VA's cash-out rules impose their own recoupment, seasoning, and benefit standards as the statute directs |
| Funding fee | 0.5%, every use | 2.15% first use · 3.3% after first use |
| Best for | Cutting the rate or fixing an ARM on a loan you already have | Tapping equity, or bringing a non-VA loan into the program |
A useful rule of thumb falls out of the fee column alone: on a $245,000 loan, the IRRRL's fee is about $1,225, while a first-use cash-out's is about $5,268. Therefore, if you don't actually need cash, the streamline is usually the cheaper door. But fees follow purpose, not preference: needing $40,000 for a roof and a debt payoff is a cash-out conversation, and no fee table changes that. Still choosing a lane? Which refinance path fits which goal in Las Vegas lays all three side by side.
The Las Vegas angle: PCS moves, kept homes, and rate windows
Southern Nevada runs on military timelines. Between Nellis Air Force Base, Creech, and one of the country's larger veteran populations, the valley is full of VA loans from every rate era — and two local patterns come up constantly in IRRRL conversations.
The kept home. Airmen PCS out of Nellis, keep the North Las Vegas or Sunrise Manor house, and rent it. Years later they assume the VA benefit on that home is frozen because they no longer live there. It isn't: prior occupancy satisfies the IRRRL certification, so the old loan can usually still be streamlined when rates make it mathematically honest. The three §3709 tests apply exactly as they would on a primary residence. For the document-by-document version, follow the step-by-step Nevada IRRRL walkthrough on our VA site when you're ready to start.
The rate-window question. Because the fixed-to-fixed floor is 0.5 points, a Las Vegas borrower's IRRRL case appears and disappears with the market. The practical move is not to watch headlines but to know your own trigger. That is the rate at which your recoupment lands inside 36 months including the funding fee in your personal math. Our current rates page shows where pricing sits. When the gap between your note rate and today's pricing approaches your trigger, run real numbers rather than illustrations.
How we run IRRRL files here
Valley West takeThe §3709 tests are a floor, not a finish line — and we treat them that way. As a lender, our IRRRL screen adds one requirement the statute doesn't. The funding fee goes into your break-even, not beside it. If your all-in recoupment doesn't clear comfortably before your realistic time-in-home, we'll tell you to keep your current loan. We put that in writing. Veterans in this valley get streamline mailers every week; the ones worth answering are the ones that survive long division. Bring your statement and your note rate. The math takes ten minutes, and "no, not yet" is a real answer we give often.
See whether your loan passes all three tests.
Seasoning dates, the rate-drop floor, and your all-in recoupment — computed on your actual loan by a Las Vegas team that works VA files every day. Ten minutes, no obligation, no pressure.
Get your fast quoteVA IRRRL FAQ
What is a VA IRRRL?
An Interest Rate Reduction Refinance Loan — the VA streamline — replaces your existing VA-backed loan with a new VA-backed loan, usually to lower the rate and payment or to move from an adjustable to a fixed rate. It's VA-to-VA only, allows no cash out, and typically closes without a VA-required appraisal or full re-underwriting, though lenders may add checks of their own.
Is a VA streamline refinance different from a VA IRRRL?
No. VA streamline refinance is the everyday name. IRRRL is short for Interest Rate Reduction Refinance Loan, the program name VA uses. Federal law spells it interest rate reduction refinancing loan (38 U.S.C. 3729(b)(4)(F)). Some lenders also say VA-to-VA refinance. Every name carries the same rules from 38 U.S.C. 3709. Those rules: the 210-day seasoning clock, the 36-month recoupment test, and the net tangible benefit floors. The FHA streamline refinance is a separate program for FHA-backed loans under HUD's rules, and it is not an IRRRL.
How soon can I use a VA IRRRL after closing my VA loan?
Under 38 U.S.C. §3709(c), the new loan can't be VA-backed until the later of: six consecutive monthly payments made on the old loan, and 210 days after the old loan's first payment due date. On a typical on-time file the 210-day prong controls, so the earliest window opens roughly seven months after your first payment comes due.
More IRRRL questions
How much does my rate have to drop for a VA IRRRL?
Per §3709(b): at least 0.5 percentage point (50 basis points) going fixed-to-fixed, and at least 2 percentage points (200 basis points) going fixed-to-ARM. The drop can't come solely from discount points — financed points trigger loan-to-value caps of 100% (one point or less) or 90% (more than one point). ARM-to-fixed can qualify on stability grounds under 38 CFR 36.4307.
Does a VA IRRRL require an appraisal or income documents?
VA generally doesn't require an appraisal or a full credit-and-income package — that's what makes it a streamline. Lenders may add overlays: payment-history review, a credit pull, sometimes an appraisal. No honest lender promises a no-document loan; expect identity, payment-history, and occupancy certification at minimum.
Cash, fees, and occupancy questions
Can I take cash out with a VA IRRRL?
No. The IRRRL amount is essentially limited to the payoff balance plus allowable costs and up to 2 discount points. Equity access — or refinancing a non-VA loan into the program — is VA's cash-out refinance. That loan carries full underwriting, an appraisal, and a 2.15% (first use) or 3.3% (subsequent) funding fee.
What is the VA IRRRL funding fee, and who is exempt?
0.5% of the loan amount on every use, financeable into the loan. Per VA, exempt borrowers include those receiving VA disability compensation (or eligible but taking retirement/active-duty pay instead). The list also covers surviving spouses receiving DIC, holders of qualifying pre-discharge ratings, and active-duty Purple Heart recipients. Later-awarded compensation with a pre-closing effective date can bring a refund.
Do I have to live in the home to use a VA IRRRL?
Not necessarily. For an IRRRL you certify that you live in the home now or previously occupied it as your home — so a former residence kept after a PCS move usually still qualifies. That's the opposite of a VA purchase (intent to occupy) and VA cash-out (you'll live in the home being refinanced).
The bottom line
The VA IRRRL earns its "streamline" name honestly: no cash out, usually no VA-required appraisal, and a closing process built around one number. That number is how fast the lower payment pays back the cost of getting it. 38 U.S.C. §3709 fences every deal with seasoning, a 36-month recoupment certification, and real rate-drop floors. As a result, a VA streamline refinance that clears the tests is one of the cleanest transactions in mortgage lending. One that fails them is a loan you were just protected from. So run the division before the enthusiasm: costs over monthly savings, funding fee included, against the time you'll actually keep the home. When you want that math done on live numbers instead of illustrations, we're ten minutes away.
Sources
- U.S. Department of Veterans Affairs — Interest Rate Reduction Refinance Loan (IRRRL eligibility, VA-to-VA requirement, occupancy certification, closing-cost options, misleading-offer warning; page last updated January 7, 2026): va.gov
- U.S. Department of Veterans Affairs — VA funding fee and loan closing costs (0.5% IRRRL fee; 2.15%/3.3% cash-out fees; exemption categories; refund rules): va.gov
- 38 U.S.C. §3709 — Refinancing of housing loans (fee recoupment ≤36 months excluding taxes, escrow, and funding fee; net-tangible-benefit 50/200-basis-point floors and discount-point LTV limits; seasoning at the later of six consecutive payments and 210 days after first payment due date; cash-out carve-out; added by Pub. L. 115-174, amended by Pub. L. 116-33): uscode.house.gov
- 38 U.S.C. §3729 — Loan fee (the loan fee table in (b)(2): row (E), interest rate reduction refinancing loan, 0.50 percent for veterans and reservists alike, with no first-use/subsequent-use split): uscode.house.gov
- 38 CFR §36.4306 — Refinancing of mortgage or other lien indebtedness (the regulation implementing 38 U.S.C. §3709: all fees and incurred costs scheduled to be recouped within 36 months of loan issuance, calculated through lower regular monthly payments; guaranty withheld until the later of 210 days from the first monthly payment and the sixth monthly payment; 50-basis-point floor on a fixed-to-fixed refinance): ecfr.gov
- 38 CFR §36.4307 — Interest rate reduction refinancing loan (current-or-prior occupancy certification, spouse-occupancy provision; payment/term/ARM-to-fixed qualifying grounds; loan amount limited to balance plus costs and 2% discount; entitlement not charged): ecfr.gov
- U.S. Department of Veterans Affairs — Cash-out refinance loan (eligibility, occupancy, non-VA-to-VA refinancing): va.gov
Across Valley West: Comparing streamline options? Our VA loan site focuses on nothing but VA lending, from IRRRLs to first-use purchases.
Keep reading
- VA LoansThe VA funding feeWhat it costs, who's exempt, and how to finance it.
- VA LoansVA loan eligibility & your COEService-era rules, entitlement math, and how the COE proves it.
- RefinanceWhen refinancing makes senseBreak-even thinking for every loan type, not just VA.
- VAVA loans in Las VegasThe purchase side of the program, start to finish.
Last updated: August 6, 2026 — vocabulary and readability pass: named the VA streamline refinance explicitly alongside IRRRL (new naming section and FAQ); re-verified all three 38 U.S.C. §3709 protections verbatim at uscode.house.gov (36-month recoupment excluding taxes, escrow, and the funding fee; 50/200-basis-point net-tangible-benefit floors with 100%/90% financed-point LTV caps; seasoning at the later of six consecutive payments and 210 days after the first payment due date); re-cited the 0.5% IRRRL funding fee to the statutory loan fee table at 38 U.S.C. §3729(b)(2)(E); recoupment worked examples recomputed independently (33.3-month pass, 76.9-month fail).
