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.
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.
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.
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).
_________________________ We're all here 'cause we've lost control.
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!
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.
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My opinion only. Not legal advice.
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.
LaLendingLady
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?