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#134702 - 11/26/03 05:44 PM Notification of Homeownership Counseling
AnnDee Offline
Member
AnnDee
Joined: Mar 2003
Posts: 62
Between a rock and a hard plac...
Could someone please confirm that the notice must be in writing? I've been asked to "double check".
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Lending Compliance
#134703 - 11/26/03 07:22 PM Re: Notification of Homeownership Counseling
Wyogirl Offline
Platinum Poster
Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
Read the BOL article from 1/22/02 called "Homeownership Counseling Requirement Revived." I can't see where you expressly must send the notice in writing, (LOL), but I don't see any other way. Maybe electronically, but I'm always looking to prove compliance. Our ITI system allows you to automatically generate the notice within the time requirements. We just stuff the envelope.

Wyogirl

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#134704 - 11/26/03 08:07 PM Re: Notification of Homeownership Counseling
Anonymous
Unregistered

The commercial lending department wants to provide the notice verbally (the consumer lending department provides a written notice). I argued that the content requirement for the notice implies that the notice should be in writing. The counter argument was that the rules never say to provide "written" notice. Management will agree with me, I'm sure, since it's safer to have a copy of a letter in a file instead of relying on lenders to document a conversation. I just didn't want to lose an argument with a lender!

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#134705 - 11/26/03 08:21 PM Re: Notification of Homeownership Counseling
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I can't prove it to you, but a verbal notice? Come on. It's stupid stuff like that, that requires the regulators to write iron-clad regulations. And then we complain because they are so legalistic and hard to read.
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#134706 - 11/26/03 08:51 PM Re: Notification of Homeownership Counseling
Tesla Offline
Power Poster
Joined: Nov 2003
Posts: 3,726
I just attended a seminar on this and the timing part of the notification requirement states "The notice must be mailed or delivered to the homeowner..." Now, one could argue you could "deliver" the notice orally, but I doubt that was the intent. I agree with the thought that it is nice to have a copy in the file rather than rely on a loan officer to document a conversation too!
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