For now it is, since it is a RESPA requirement and such a property is exempt under section 1024.5(b)(1). That exemption goes away on 8/1/2015.
That said, don't forget that there are two instances under Regulation Z in which the borrower is required to obtain homeownership counseling prior to consummation of the loan. You may need to provide such borrowers with a list so they can go arrange for the counseling:
* First time borrower in connection with closed-end consumer credit transaction secured by a dwelling (other than a reverse mortgage or one secured by an interest in a time-share plan) that may result in negative amortization [1026.36(k)]
* A high-cost mortgage [1026.34(a)(5)]