If we have a HCM does the customer have to attend homeownership counseling and provide proof of that prior to closing? Is this only for customers who are first time home buyers experiencing negative amortization?

1026.34(a)(5) Pre-loan counseling. (i) Certification of counseling required. A creditor shall not extend a high-cost mortgage to a consumer unless the creditor receives written certification that the consumer has obtained counseling on the advisability of the mortgage from a counselor that is approved to provide such counseling by the Secretary of the U.S. Department of Housing and Urban Development or, if permitted by the Secretary, by a State housing finance authority.

rlcarey, thanks for this information as I was looking in the wrong section - maybe under RESPA HCM requirements.

RESPA HCM?

There are no special requirements in RESPA for High Cost Mortgage Loans.

1024.20's requirements for providing a list of homeownership counseling organization applies to all federally related mortgage loan apps.