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#1922944 - 05/14/14 01:21 PM Homeownership Counseling Compliance
sway Offline
100 Club
Joined: Feb 2011
Posts: 128
The application system is set up so that a pop-up is generated which forces the MLO to do 2 things: 1. Click on a link and visit the CFPB website and print off the homeownership counseling list 2. Confirm the list was provided to the applicant. A walkthrough of the process shows that that the link generates a list based on the applicant’s current address. Additionally, the MLO must confirm that the list was provided to the applicant by selecting “Yes”. If the MLO clicks “No”, the application process will not move forward. When the applicant selects “Yes” loan notes are generated that show the counseling notice was provided. It seems I would just need to review the loan notes (date and note list was provided). Loan files do not contain the actual list given to the applicant. Does this seem adequate?

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HOEPA and Homeowner Counseling Rule
#1923237 - 05/14/14 07:01 PM Re: Homeownership Counseling Compliance sway
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The only concern I see is that the applicant can request that the list is generated based on another zip code than the one at the applicant's current address.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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