Anyone know if the 1024.20 requirements related to the homeownership counseling requirements would apply to FHA Title I loans? The program guidelines state "Housing counseling is not required for participation in the program." Nothing we could find in the documentation says it is required. However, I don't see it as explicitly exempt under RESPA. Anyone have any thoughts?

Homeowner's counseling is not required on 99.999% of loans for which you are required to deliver the disclosure. What does a Title I have to do with the delivery of the list?

I agree it's not required. However, the department who handles our Title I loans states that it is that statement exempts them from also providing the list.

Not sure what to say, but an FHA loan is not exempt from any disclosure or other requirements found in RESPA, except the transfer of servicing requirements when the loan is assigned to the FHA.

That's where I stood, but thank you for increasing my confidence in addressing this issue.