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Regarding the new homeownership counseling notice required beginning 1/10/13 that we can download from the CFPB’s website using the borrower’s home zip code, that must be provided within 3 days of application for RESPA loans, will we be requried to place a copy of that notice in each loan file, or will the fact that our procedures require us to provide the list within 3 days of application be sufficient?
You may place a copy of the list in the file, but it isn’t required. If you have the copy in the file I would document on the copy when it was delivered. If you decide not to keep a copy you’ll need detailed procedures of how and when the list should be pulled; you should also add either a memo to the file or document it on your loan checklist that it was delivered and when.
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