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#1928149 - 05/30/14 06:45 PM Homeownership Counseling Acknow. trumps list?
sway Offline
100 Club
Joined: Feb 2011
Posts: 128
I am reviewing for compliance with the homeownership counseling rule and had a question.

Does an acknowledgement signed by an applicant confirming they received the homeownership counseling list trump the actual list provided to the applicant? I have an acknowledgement signed and dated 3 days after the application stating they received the list for their area. Do I need to review a copy of the actual list to confirm it was actually sent and relevant to their current address? I don't know how much standing this acknowledgement form has as I see situations in which the acknowledgement document is signed at/or before closing. I just wanted some thoughts on this.

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HOEPA and Homeowner Counseling Rule
#1928154 - 05/30/14 07:01 PM Re: Homeownership Counseling Acknow. trumps list? sway
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
There is no signature requirement on the homeownership counseling disclosure nor is there any specific retention requirements. Delivery documented through procedures such as acknowledgments or cover letters should all that is necessary, unless you have evidence that it is not happening as documented. I would test by going to the people that produce them and say, OK, I submitted an application from zip code XXXXX - show me how you produce the disclosure.
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