Homeownership Counseling Procedures

Now that homeownership counseling is a permanent requirement, the FFIEC has published examination procedures. The procedures themselves are fairly simple. Examiners must obtain the answers to two questions: does the institution notify homeowners as required, and does the institution provide eligible homeowners with the names of approved nonprofit counseling organizations. As an internal checklist, this isn't much help.

What is useful, in the procedures, is the concise (2 pages) discussion of the rule and its requirements. This could be a useful tool for training and for inclusion in your compliance manual.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 7, 7/03