No, it’s not the day that Dodd-Frank gets repealed, but nice try. The CFPB finally released the homeownership counseling “tool” that will assist credit unions in meeting the requirement to provide mortgage applicants with a list of local homeownership counseling organizations.
However, along with the tool comes some additional provisions regarding the list, specifically if credit unions decide to build their own list and not use the “tool.” I would suggest that credit unions use the tool if at all possible, rather than build your own list.
Here are some highlights of the “interpretative rule.”
- The list must contain ten HUD-approved housing counseling agencies
- You must provide counseling organizations in the loan applicant’s location. You should use the borrower’s zip code related to his/her current address to generate a list of the ten closest HUD-approved housing counseling agencies.
- The credit union will comply if it provides the following data fields for each housing counseling agency on the list to the extent that they are available through the HUD API: agency name, phone number, street address, city, state, zip code, website URL, email address, counseling services provided, and languages spoken. (The “tool” will generate this information.)
- The list must contain the following disclosure: The counseling agencies on this list are approved by the U.S. Department of Housing and Urban Development (HUD), and they can offer independent advice about whether a particular set of mortgage loan terms is a good fit based on your objectives and circumstances, often at little or no cost to you. This list shows you several approved agencies in your area. You can find other approved counseling agencies at the Consumer Financial Protection Bureau’s (CFPB) website: consumerfinance.gov/mortgagehelp or by calling 1-855-411-CFPB (2372). You can also access a list of nationwide HUD-approved counseling intermediaries at http://portal.hud.gov/hudportal/HUD?src=/ohc_nint. (Again, the CFPB’s tool will generate a list that has this disclosure.)
So, start preparing for the January 10, 2014 deadline by determining how you will provide the list and what policies, processes and operations need to change in order to do so.