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#1884328 - 01/08/14 07:56 PM Re: Homeownership Counseling Organizations - List Ninky
BankingNut Offline
Member
Joined: Apr 2010
Posts: 90
Hi everyone. I hope this does not get stuck on the bottom of the page. Does anyone have any language that they are giving their customer to affirm (sign) that they received a copy of this?

Two of our secondary market investors are requiring that we prove the customer received a copy.

Thank you!

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HOEPA and Homeowner Counseling Rule
#1884331 - 01/08/14 08:02 PM Re: Homeownership Counseling Organizations - List Ninky
rsanders Offline
Member
Joined: Feb 2010
Posts: 72
Our loan system added a form.

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#1884337 - 01/08/14 08:17 PM Re: Homeownership Counseling Organizations - List Ninky
Live&Learn Offline
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Live&Learn
Joined: Aug 2012
Posts: 241
South
Do we need to keep a copy in the loan file to prove we gave to the customer?

(I didn't see the third page of this thread.. sorry!)
Last edited by Live&Learn; 01/08/14 08:18 PM.
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#1884339 - 01/08/14 08:21 PM Re: Homeownership Counseling Organizations - List Live&Learn
BankingNut Offline
Member
Joined: Apr 2010
Posts: 90
Originally Posted By: Live&Learn
Do we need to keep a copy in the loan file to prove we gave to the customer?



No, you should develop a process demonstrating that you provide this to all of your customers. However, we have secondary market investors who want to see a signed disclosure. In order to sell to them, we have to do what they say.

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#1884435 - 01/08/14 10:33 PM Re: Homeownership Counseling Organizations - List Ninky
#Just Jay Offline
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Cheeseheadland
Just printing two copies, one to hand to the borrower, and one for the file, per investor requirements.
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#1884581 - 01/09/14 04:24 PM Re: Homeownership Counseling Organizations - List Ninky
RR Joker Offline
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RR Joker
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The Swamp
The reason you may want to keep a copy in your file is to show that you gave a list current within 30 days.

The lists out on the website will print a print date if you do NOT use the .pdf version.
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#1884631 - 01/09/14 05:33 PM Re: Homeownership Counseling Organizations - List Ninky
SLU Voice Offline
Gold Star
SLU Voice
Joined: Apr 2004
Posts: 288
Hammond, LA
We use Laser Pro for in-house loans, and Calix for secondary market loans. Both have added a form for Acknowledgement of Receipt of Counselor List. There is a line for the applicant to sign and we keep a copy in the file. We will use the list of counselors that are on the CFPB site.

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#1884837 - 01/09/14 08:53 PM Re: Homeownership Counseling Organizations - List Ninky
MaddieO Offline
New Poster
Joined: Jul 2007
Posts: 5
I do not see a requirement for customer confirmation of receipt of the list, so what is everyone doing to document compliance?

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#1884841 - 01/09/14 08:57 PM Re: Homeownership Counseling Organizations - List Ninky
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
Deleted
We have the Homeownership Counseling Org List on our early disclosure checklist. This checklist is completed BEFORE the disclosures go out (vs. during a post-booking review).
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#1885058 - 01/10/14 03:02 PM Re: Homeownership Counseling Organizations - List Ninky
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
It's included in our "intent to proceed" letter.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1885065 - 01/10/14 03:05 PM Re: Homeownership Counseling Organizations - List Ninky
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,781
The Mitten State
It is also included in our letter.
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#1886275 - 01/14/14 02:53 PM Re: Homeownership Counseling Organizations - List Ninky
LA LA Offline
Junior Member
Joined: Nov 2008
Posts: 38
Does anyone know if the CFPB is okay with the counseling being online vs. telephone or in person? Our closest counselor is 120 miles and they offer online training, which is essential in our state. In addition, the counselor will discuss the consumer's early/closing disclosures prior to certification. Someone thought they read where online training will not be acceptable, so I thought I better ask the experts!

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#1886295 - 01/14/14 03:11 PM Re: Homeownership Counseling Organizations - List Ninky
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Not that I know of or see in the regulations. I thought I remember in the actual rule discussion that it was acceptable. It's not reasonable to expect someone to go an unreasonable distance to get the required counseling...there are way too many remote areas with no couseling nearby.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1886296 - 01/14/14 03:13 PM Re: Homeownership Counseling Organizations - List Ninky
LA LA Offline
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Joined: Nov 2008
Posts: 38
That was my thinking too! Thank you.

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#1886301 - 01/14/14 03:15 PM Re: Homeownership Counseling Organizations - List Ninky
LA LA Offline
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Joined: Nov 2008
Posts: 38
By the way, there are homeownership counselors closer and HUD approved; however, they do not appear on the CFPB list. They are offering the same online training as the ones on the list. Do we dare not use them because they are not on the list? This counselor would be much closer to us and our customer could possibly drive there and do it in person.

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#1886304 - 01/14/14 03:24 PM Re: Homeownership Counseling Organizations - List Ninky
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
From what I can tell, so long as they are HUD approved, the are acceptable.

Also, have you checked this additional list on the Bureau's site to see if they may be on it?

http://portal.hud.gov/hudportal/HUD?src=/ohc_nint
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1886305 - 01/14/14 03:24 PM Re: Homeownership Counseling Organizations - List Ninky
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Sorry, that HUD list actually came from a link on the Bureau website here:

http://www.consumerfinance.gov/find-a-housing-counselor/
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1886419 - 01/14/14 05:33 PM Re: Homeownership Counseling Organizations - List Ninky
LA LA Offline
Junior Member
Joined: Nov 2008
Posts: 38
I had already checked the list of additional counselors and this particular servicer is not on there. Thank you for your assistance.

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#1947068 - 07/29/14 08:11 PM Re: Homeownership Counseling Organizations - List SLU Voice
LaLendingLady Offline
Junior Member
Joined: Apr 2014
Posts: 39
Originally Posted By: SLU Voice
We use Laser Pro for in-house loans, and Calix for secondary market loans. Both have added a form for Acknowledgement of Receipt of Counselor List. There is a line for the applicant to sign and we keep a copy in the file. We will use the list of counselors that are on the CFPB site.


how do you print one from laserpro for helocs with the app date and applicant's name and address?

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