38 CFR 13.280 Every required component, on every pack — verified, not assumed

The most rigorous 38 CFR 13.280 accounting pack a VA fiduciary can file.

HubReady assembles a documentation-complete annual fiduciary accounting package — every required component, every supporting exhibit, the reconciliation, and the 30-day deadline calendar — checked against the letter of 38 CFR 13.280 before a specialist releases it.

Every component of 38 CFR 13.280Six statutory accounting elements, gate-checkedBank-statement reconciliation · expenditure categorizationSpecialist release on every pack5-business-day SLA
Why filings fail

A single missing element can trigger a misuse investigation.

A VA fiduciary's annual accounting is only as strong as the documentation behind it. Miss one of the six required components, fail to reconcile a single transaction, mis-categorize an expenditure, or miss the 30-day deadline — and the filing can be rejected, trigger a VA misuse investigation, or be treated as prima facie evidence of embezzlement under 38 CFR 13.280.

Most fiduciaries are family members — spouses, adult children, parents — with no bookkeeping background, appointed by VA's own priority rule (38 CFR 13.100(e)). They run this by hand, from memory, once a year. The regulation has not been read end-to-end since the last time it mattered. That is exactly where completeness gaps hide.

HubReady exists to close that gap with a single, exhaustive standard applied identically to every file.

1 of 6
missing accounting components is enough to jeopardize a fiduciary appointment
The benchmark

Measured against the letter of the regulation — component by component.

We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of 38 CFR 13.280. These are the provisions each pack is held to.

38 CFR 13.280(a)

Six accounting components

Itemized income, itemized expenses, beginning balance, ending balance, reconciliation to bank statements, and supporting receipts — all present, or the pack does not release.

38 CFR 13.280(b)

30-day deadline

The filing date is verified to fall no later than 30 days after the close of the accounting period, computed deterministically — never estimated.

38 CFR 13.280(c)

Corrected accounting within 14 days

If VA issues a discrepancy notice, a corrected accounting is due within 14 days. The pack includes a pre-formatted correction template.

38 CFR 13.280(d)

Prima facie evidence of embezzlement

Willful neglect or refusal to file a proper accounting is, by regulation, prima facie evidence of embezzlement. The pack includes a compliance checklist to avoid this presumption.

38 CFR 13.280(e)

Expenditure categorization

All expenditures are categorized according to VA's expenditure taxonomy (e.g., food, housing, medical, education) — no guesswork.

38 CFR 13.280(f)

Supporting exhibits

Bank statements, receipts, and any fee authorization documentation are assembled and cross-referenced to the accounting ledger.

How a pack is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human specialist signs every release. That order is never reversed.

01

Gap Scan

Upload the fiduciary's bank statements and receipts. We return a free completeness read: which accounting components and supporting documents you already have, and which are missing.

02

Evidence & reconciliation

As your authorized clerical agent, we extract transactions, categorize expenditures per VA taxonomy, and reconcile the ledger to the penny against bank statements.

03

Grounded drafting

The six accounting components are drafted from your validated data and the 38 CFR 13.280 rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

Income and expenses reconcile to the penny; the 30-day deadline is verified; the component checklist is resolved; any discrepancy is flagged. Any failure blocks release.

05

Specialist release

An accounting specialist reviews the exception queue and signs the release. High-value or complex accounts route to a CPA review first.

06

Delivery

You receive the pack: completed VA Form 21P-4706b, supporting exhibits, reconciliation log, compliance checklist, and the 30-day calendar — ready for the fiduciary to sign and submit via FAST.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No pack ships without a human signature.
5 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
6
Accounting components
Every 38 CFR 13.280 component, every applicable file.
Why HubReady

Built to be the most thorough option a fiduciary has.

Documentation-complete, by design

The deliverable is completeness itself — every accounting component and supporting document accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never contact the beneficiary, give legal advice, or act as the fiduciary.

Engagement

Flat fee, per released pack. No hourly billing, ever.

Simple, predictable, and aligned with a documentation standard — not a percentage of any benefit amount.

  • A free Gap Scan before you commit — see exactly what is missing.
  • One flat fee per released Annual Accounting Completeness Pack; disclosed pass-through fees for any third-party searches.
  • Optional fixed-fee CPA review for high-value or complex accounts.
  • Optional Correction Add-on for the 14-day corrected accounting template, pre-dated to your VA discrepancy notice.
FAQ

Questions, answered precisely.

Is HubReady a law firm?
No. HubReady, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. CPA review is available and recommended for high-value or complex accounts.
Do you contact the beneficiary or manage the benefits?
Never. HubReady is not a fiduciary and does not contact beneficiaries or manage VA benefits. The fiduciary remains the appointed party responsible for all decisions and for submitting the accounting to VA.
What makes a pack 'complete'?
Completeness is defined by the regulation: the six 38 CFR 13.280(a) components present, the 30-day deadline verified, expenditures categorized per VA taxonomy, bank statements reconciled, and supporting exhibits assembled. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released pack. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released pack, plus disclosed pass-through costs. No hourly billing and no percentage of any benefit amount or recovery.

See what's missing before it triggers an investigation.

Start with a free Gap Scan. Send your bank statements and receipts and we'll return a completeness read against every component of 38 CFR 13.280.

Documentation-completeness service · not legal advice · the fiduciary signs and submits every filing.