Does the 210-day rule apply to VA cash-out?

Yes, when you use a VA cash-out refinance to replace an existing VA-backed loan. The VA handbook distinguishes two types. The difference matters if your first payment was due on one date and actually made on another.

Existing loan and new refinanceHow VA measures seasoning
VA to VA, Type I. The new loan amount including the funding fee is at or below the payoff.Allow at least 210 days from the first scheduled payment due date and make six consecutive monthly payments.
VA to VA, Type II. The new loan amount including the funding fee exceeds the payoff.Allow at least 210 days from the date you actually made the first monthly payment and make six monthly payments. The handbook says those payments can be nonconsecutive for this test.
Non-VA loan to VA cash-outVA’s VA-to-VA seasoning rule does not apply. The lender may have its own requirements, and the loan still has to meet the other VA cash-out rules.

Which date should you put on your calendar?

Suppose your first payment was due June 1 and you made it June 8. In this example, the 210-day mark is December 28 for Type I and January 4 of the following year for Type II. Both assume you have met the applicable payment requirement by that date. Ask for a servicer payment ledger so we can confirm the dates, the number of payments, and the refinance type before you plan around a closing.

Your payoff can differ from the balance on your statement. Have the lender compare the payoff and proposed new loan amount, including any financed VA funding fee. Ask for a separate review if you had a modification, forbearance, or unusual payment history.

Related reading VA cash-out refinance guide and IRRRL vs. VA cash-out.

Sources

VA Lenders Handbook, Chapter 6 and 38 U.S.C. § 3709.