HOMEOWNERSHIP COUNSELING POLL
Compliance Masters Group
July 18, 2014
A recent poll of our Compliance Master Group members centered on the issue of homeownership counseling rules. There were no huge surprises. We got a lot of confirmation of what we expected to see:
- Providing the list of counseling organizations is not a significant burden;
- The potential burden on consumers is high, but unrealized, since most of our members have few, if any, transactions subject to Section 32 of Regulation Z or that have potential negative amortization.
1. Considering a typical Homeownership Counseling List you might pull, what is the distance of the counseling organization farthest from your applicant?
a. Less than 25 miles ( 4%)
b. 25-50 miles ( 30%)
c. 51-100 miles ( 26%)
d. More than 100 miles ( 17%)
No Answer ( 22%)
2. Considering a typical Homeownership Counseling List, what is the distance of the counseling organization closest to your applicant?
a. Less than 25 miles (30%)
b. 25-50 miles (35%)
c. 51-100 miles ( 9%)
d. More than 100 miles ( 4%)
No Answer (22%)
3. What is your process for obtaining the list of homeownership counselors?
a. Our loan origination software automatically generates the list. (17%)
b. Someone in our bank pulls the list from the CFPB website. (65%)
c. Other ( 0%)
No Answer (17%)
4. What is your process to document compliance with the requirement to provide a list of homeownership counseling organizations?
a. We keep a dated and signed copy of the list in the file. (13%)
b. We keep a dated copy of the list in the file. (13%)
c. We have a separate acknowledgement for the customer to sign stating they received the list. (39%)
d. Our procedures show we comply and we do not retain documentation in our files. ( 9%)
e. Other ( 0%)
No Answer (26%)
5. Have you had any issues/difficulties with accessing a list of counselors?
a. Yes ( 0%)
b. No (74%)
No Answer (26%)
6. Has your institution had to obtain certification of pre-loan counseling as a result of a high-cost mortgage loan?
a. Yes ( 0%)
b. No (70%)
No Answer (30%)
7. Does your institution offer loans that may result in negative amortization?
a. Yes ( 0%)
b. No (78%)
No Answer (22%)
8. Has your institution made a loan to a first-time borrower that may result in negative amortization for which you had to obtain certification of pre-loan counseling?
a. Yes ( 0%)
b. No (78%)
No Answer (22%)