Needing clarification on the HomeOwnership Counseling discolure. I am having difficulties locating if this is only required for a consumer loan. What if a borrower is purchasing a rental home? Is it required for that application?

It is required on all RESPA covered loans.

Where did you get that guidance?

1024.20

I was under the impression this only applied to "federal-related " mortgages meaning FHA or VA transactions. Is this not correct?

No. "Federally related" in this context uses the same language that RESPA itself uses to define loans subject to RESPA, which i believe basically is just a way to say "loans made by banks or other institutions that are subject to federal banking laws".

thank you.......... and Yikes. To pull this information manually since it's zip code specific will be cumbersome.

It's actually a pretty simple list...input the zip and print out the list.

Is there an exemption for small servicers regarding providing the home ownership counseling disclosure? I am receiving conflicting information.

No

Our Commercial Lending Departemnt originates some 1-4 family non-owner occupied loans . Am I correct in saying these are still covered under this ruling?

The requirements are under RESPA (1024.20), so in general I don't think commercial loans are covered.

I keep getting confused between the appraisal disclosure requirements and the counseling notices... ahhhh

If it's covered by RESPA, yes. So, if the loan is for consumer PURPOSE, regardless of what the security is..then yes, it applies.

One more question, the CFPB page for the disclosure gives you the option to print or save the disclosure...the printed version has a date (from the printer) the saved version does not. Printing, scanning and uploading the printed version is cumbersome, but the saved version has not date to verify compliance with the 3 day requirement. Does anyone think the CFPB will take issue even though it is their fault there is no date on the saved version?

We are printing and sending the printed version but for a slightly different reason YOS. We are using that one to prove it was the most recent one within 30 days of application .

Are you having issues with it cutting of the right side of the page? We are.

YOS you might have to change some of your printer settings if you are printing it as PDF

I haven't had that problem Yos.

Make sure to use the "print this page" icon just below the map. If you just use the print tool from your browser it will cause the page format to do weird things.

Has anyone encountered co-borrowers that do NOT currently live together? Do you need to send out a Counseling Disclosure to each borrower using their individual current zip codes?

From 1024.20:
If there is more than one loan applicant, the required list of homeownership counseling organizations may be provided to any loan applicant with primary liability on the mortgage loan obligation.

We just had a notice and list generate for the Counseling List requirement on a construction renewal. I don't see any exemptions for a renewal loan. Just want to verify that I am not missing anything and it should be provided on a renewal?

This is a home improvement remodel, not a true construction loan.

If it was a refinance, it would be required.