I've recently completed an audit and discovered we have not been disclosing the 10 closest organizations on the Homeownership Counseling List....we now have procedures in place that will produce lists in a compliant manner. The procedures do require a few manual steps to ensure the inclusion of the 10 closets organizations..so there is a chance that they may not always be compliant....

I'm trying to rate risk.....what is the penalty for not providing a compliant Homeownership Counseling List?

Thank you for any feedback.

There are no statutory penalties in RESPA for disclosure violations.

What does this mean "The procedures do require a few manual steps to ensure the inclusion of the 10 closets organizations.." You just plug in the zip code into the list generator. What manual steps are you doing?

The list is generated in Encompass.....for Encompass to draw info on all organizations available, several boxes for different types of agencies need to be checked...we were only checking one of the boxes, so it was not drawing from all available to provide the 10 closest...it only provided the 10 closest from the one agency selected. (this was per instructions from Encompass)

So the manual process is to make sure all boxes are checked when pulling the list...

Hope that makes sense...

So if there are no statutory penalties...the risk associated with non-compliance is low....????

I didn't say that. I'm saying it is going to be left to the discretion of the examiner. The consumer does not have automatic civil penalties available.

I wouldn't sweat this. You've found the issue & fixed it. Move on.

Thanks