Thanks....it must be something with my computer....it is giving me a "file cannot be saved" message.

I didn't try to save the file. I bookmarked the link. See if IT can help you!

good idea.

I hit the "Print list" button and the date printed on the bottom along with the web address.

Dani, that way does give a date. It is not the "pretty pdf" like the other choice, but it does have a date and source data!

Of the ten on my list, one says service not available. So how would I find one to replace it, or don't I have to since technically I printed their list.
I'm leaning towards, just print their list.

It's their list - go with it.

A major vendor just provided a notice to use for the Home Counseling requirements but it requires the borrower to pull the list themselves. It includes a link to the CFPB and basically says "do it yourself". They state the 11/14/2013 FR permits this and gives them until July 10, 2014 to automate the population of the list of counselors.

I don't see anything in the FR about July 10, 2014 and I don't think this is permitted but our lenders are doing a happy dance because I previously told them they had to print the list out.

Did I miss something?

Tell your lenders to calm down. The regulation clearly requires that "the lender must provide the loan applicant with a clear and conspicuous written list of homeownership counseling organizations . . ." [12 CFR 1024.20(a)(1)]. {emphasis mine}

I highly doubt that providing a URL to an applicant would qualify as providing a written list.

Well unfortunately, I was wrong. I read the Final Rule but there is a 11/8/13 Bulletin that says:

Interim Option 3 - The third, interim option acknowledges that system updates will be required in order to take advantage of the second option. As mentioned above, the CFPB believes that it may take 6 months to implement the system updates. Thus, creditors would not be able to take advantage of Option 2 on the January 10, 2014 effective date. Accordingly, while creditors are making a good faith effort to implement Option 2, creditors may fulfill the housing counselor disclosure requirement by directing consumers to the CFPB’s housing counselor website, using sample text provided in the guidance bulletin.

http://files.consumerfinance.gov/f/20131...equirements.pdf

I gotta remember to read the Rule, any updates to Rules, the bulletins, guidances, blogs and wherever else information may hide before I open my big mouth!

Am I reading the reg right that we could the list out for our most popular zip codes and just update our print out every 30 days?

Sure, as long as you can be sure to send the right list based on the customer's location. We determined internally that it would take as many steps to go to the website and print out the list individually as it would take to shuffle through the possible zip codes and find the right document to include with the borrower's other documents. And you'd still have to print one out if you had an outlier anyway.

True. I just want the least steps involved. I emailed our software vendor to see if anything will be possible through them. I will wait to see their response and go from there.

Also, does the list have to be given on HELOCs?

Yes, I believe they do since this section has been expanded to include HELOCs.

Our vendor is providing the temp notice of directing the borrower to the website while they update their system to generate the list.

I would like to take advantage of using their notice because I think it will cause less errors and confusion. However, I'm concerned that an examiner would scrutinize the process because we could have generated the list ourselves using the tool provided.

ahkcompliance - we must have the same vendor. Unfortunately, I am not the only one to get the emails from the vendor and since everyone likes to take the easy way out, the departments ran with it. I, personally, would have said just print it out and not given them that option. But since they made the decision, I will hang on to the Bulletin from the CFPB saying it is OK to do it this way to defend their decision.

Thanks for your input Tesla! Luckily for me I am the one to actually pay attention to the notifications! I would like to just go with the vendor but am hesitant. Also afraid lenders will forget to print out the notice and retain a copy in file.

When I pulled up the list today I had several duplicates. In fact the first 9 listings only represented 3 different counselors. Has anybody else experienced this? I have looked at the list before and it wasn't like that.

I look at it this way. The Congress and the regulators created this nightmare - it is not the bank's list. I would print it off, no questions asked and hand it to the loan applicant. If the loan applicant has questions or comments, have your Congressperson's phone number handy.

Yes, over the weekend they were fine. Then yesterday, it displayed 2 of each counselor. Now today, it's displaying 3 of each, limited to the first 10, so you're really only getting 4 counselors.

Hmmm......interesting. Maybe they will correct that soon.

I went to print out a list and got healthcare Just kidding, but for our rural branches there is typically only one counselor within a 60 mile range. Good thing we don't do HOEPA loans.

But doesnt the list need to be given to all applications for purchae money and open end credit secured by the consumer's principal dwelling. It just only High Cost that are required to get counseling????

Yes, the list has to be given to all.

You have to give a list on all RESPA covered loans. If your loan meets other requirements for actual counseling under Reg Z you give a list AND verify counseling was completed.