I apologize if this was already asked.

Our LOS allows us to select ALL counseling servicer types (e.g,Pre-Purchase Counseling, Loss Mitigation, etc) in order to match the counseling agencies when a zipcode is entered on the CFPB website. That appears to be the "safest" thing to do.

I didn't find anything in the regulation or the interpretive rule that requires the list to match, only that we have to list at least 10.


So, if you are using an LOS to generate the list, are you generally matching the CFPB tool list or do you try to search for agencies based on service type?
Example: On a purchase transaction, you search for "Pre-Purchase Counseling (PPC) and Pre-Purchase Homebuyer Education (PPW) to generate of a list of 10 agencies that provide those services.

The CFPB Website tool http://www.consumerfinance.gov/find-a-housing-counselor/ lists only the 10 closest based on zip code, and there doesn't appear to be an option to search based on services offerred by each agency.

I would imagine you'd simply be creating extra work for yourself to generate a list that only includes agencies providing relevant services - and of course, potential for error - but I can see where a borrower may appreciate the extra effort.

Our LOS requires the loan officer to select all 18 boxes (no select all button) in order to generate a list that matches the CFPB generated list, so we're actually trying to create less "clicks" by allowing them to select only 1 or 2 services types based on the type of transaction.

That's the idea anyway.

We matched the list that was generated directly from the CFPB web site with the list that our LOS generated. In order for our LOS to generate the exact same list as the CFPB, we have to check all the options.

It's kind of a pain, but I believe they are working on creating a "select all" option to make it easier.

We probably have the same LOS. Do you see a problem though, with selecting only a few of the service options, as long as it provides 10?

Our LOS is at least smart enough to tell us if you selected a service option that doesn't provide at least 10 options in the area.

We tried several different iterations of options checked, and the only way that we could match what we got from the CFPB web site was to check all the option types. I think it's a little goofy, especially since some of the counseling types are not really germane to home purchase or refinancing, but as long as you match the CFPB output I don't see how you can be criticized.

And unfortunately, that's what it's become now, right? Strict compliance with the regulations trumps usefulness to the customer.

We are converting to a new LOS and tested selecting all the types, since they have to be manually checked by the LO. However, the system generated a list that has more than 10 options in the area, which is overkill. It also didn't totally match the CFPB list.

I'm recommending our LOs select pre-purchase counseling and home improvement/rehabilitation counseling in order to cover both purchases and refis. Seems to be the best solution operationally and complies with the 'spirit of the law', IMO.