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CFPB Is Implementing Counseling Class Guideline On January 10, 2014

By
Mortgage and Lending with George Souto NMLS #65149 FHA, CHFA, VA Mortgages NMLS #65149

CFPB Is Implementing Counseling Class Guideline On January 10, 2014 .  As I stated at the end of my blog  "CFPB Mortgage QM Rules Overviw" there is a Consumer Financial Protection Bureau (CFPB) Guideline going into effect on January 10, 2014 which has not been talked about much and not well known.  The new CFPB Guideline will require ALL Lenders to include a written list of Homeownership Counseling Organizations with EVERY Loan within 3 days of Mortgage Application.

The new CFPB Counseling Class Guideline requires Lenders to give Borrowers a written list of Homeownership Counseling Organizations with EVERY Loan within 3 days, BUT does not require Borrowers to take the Counseling Classes.  Also Lenders are not required to advise Borrower to take the Counseling Classes, but simply to make them aware of their availability.

The CFPB Guideline requires the list of Homeownership Counseling Organization to include:

  • The Agencies closest to the Zip Code of the Borrower's current address (not the address of the property they are purchasing).
  • The List MUST contain the TEN (10) closest approved Housing Counseling Agencies.
  • The List MUST contain the following verbiage:

The counseling agencies on this list are approved by the U.S. Department of Housing and Urban Development (HUD), and they can offer independent advice about whether a particular set of mortgage loan terms is a good fit based on your objectives and circumstances, often at little or no cost to you. This list shows you several approved agencies in your area. You can find other approved counseling agencies at the Consumer Financial Protection Bureau’s (CFPB) website: consumerfinance.gov/mortgagehelp or by calling 1-855-411-CFPB (2372). You can also access a list of nationwide HUD-approved counseling intermediaries at http://portal.hud.gov/hudportal/HUD?src=/ohc_nint

The HUD link above takes the Borrower to a link which will then provide links to Housing Counseling Agencies for each state, but there is a more direct link which will provide the 10 closest Housing Counseling Agencies by Zip Code http://www.consumerfinance.gov/find-a-housing-counselor/

This is in my opinion another example of a CFPB Guideline which creates more work for Lenders, kills more trees, and will be use little if at all by Borrowers.  I say this because presently Borrowers HAVE to attend Counseling Classes if they are doing a Downpayment and/or Closing Cost Assistants Loan (DAP), and do not attend most of the time until the last minute, and only after being reminded to do so several times.

CFPB Is Implementing Counseling Class Guideline On January 10, 2014.  This may seem like a great idea, but in my opinion it is another feel good guideline which will do very little more than create more jobs at the cost of the Taxpayer. 

 

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 Info about the author:

George Souto NMLS# 65149 is a Loan Originator who can assist you with all your #FHA, #CHFA, and #Conventional #mortgage needs in Connecticut. George resides in Middlesex County which includes #Middletown, #Middlefield, #Durham, #Cromwell, #Portland, #Higganum, #Haddam, #East Haddam, #Moodus, #Chester, #Deep River, and #Essex. George can be contacted at (860) 573-1308 or gsouto@mccuemortgage.com

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George Souto
NMLS# 65149

C (860) 573-1308
CALL 7 Days/Wk
Fax (860) 760-6891

Email Me
About Me
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I am a Mortgage Loan Officer who can assist you with all your mortgage & refinancing needs in
CT, and RI

I can assist you with your Conventional,
FHA, CHFA, VA, USDA, & 203K loan programs.

I reside in Middlesex County which includes Middletown, Middlefield, Durham, Cromwell, Portland, Haddam. E. Haddam, Higganum, Chester, Essex, Deep River.

 

Comments (8)

Joe Petrowsky
Mortgage Consultant, Right Trac Financial Group, Inc. NMLS # 2709 - Manchester, CT
Your Mortgage Consultant for Life

I can tell you all of the lenders that I work with are scrambling to get ready for all that is required of them. One thing I know for sure, all these new regulations will not speed up the process when it comes to getting a mortgage closed.

Dec 30, 2013 07:06 PM
Potranco Realty
Potranco Realty - San Antonio, TX
"Sold with Potranco Realty"

Hi George, it sounds like a good program however like you say it's more work for you and other Lenders and will use more paper. I hope buyer will benefit from it but do they really? I'm thinking not when they have a reputable Mortgage Lender like yourself they know all they need to hopefully. Just CFPB wanting to be in total Charge of everyone.

Dec 30, 2013 08:25 PM
Ritu Desai 703-625-4949
Samson Properties - Chantilly, VA
Northern Virginia,Washington DC & Maryland Realtor

Thanks George for sharing this update. It will be interesting how many of the home buyer actually take the opportunity to attend the class

Dec 30, 2013 09:19 PM
Ginny Gorman
RI Real Estate Services ~ 401-529-7849~ RI Waterfront Real Estate - North Kingstown, RI
Homes for Sale in Southern RI and beyond

So George I am prepared to tell buyers it is a longer lending process...Have a Happy New Year...i have multi offers going on in a house that needs decision by tomorrow!

Dec 30, 2013 09:26 PM
Dick Greenberg
New Paradigm Partners LLC - Fort Collins, CO
Northern Colorado Residential Real Estate

Hi George - I checked the link, and of the 10, there are 3 that would be within reasonable distance - the rest are all down in the Denver area. You're right that it's pretty severe overkill. Have a Happy New Year!

Dec 31, 2013 12:33 AM
Debbie Reynolds, C21 Platinum Properties
Platinum Properties- (931)771-9070 - Clarksville, TN
The Dedicated Clarksville TN Realtor-(931)320-6730

These counseling classes are helpful for new buyers. There is so much to more to buying a home than just making the offer.

Dec 31, 2013 12:53 AM
George Souto
George Souto NMLS #65149 FHA, CHFA, VA Mortgages - Middletown, CT
Your Connecticut Mortgage Expert

Joe you are right, and we will be the ones to take the heat for it and not the CFPB

Bob this is nothing more than a "feel good" guideline for them, but in reality it will accomplish nothing.  I can't imagine any Borrower volunteering to sit through one of these classes.

Ritu, I am going to be surprised if any Borrowers take the class, but it is more paper work for us and possible fines if for some reason the Borrower does not get the information withing the 3 day window.

Ginny, there is a possibility it could add to the approval process if the Borrower decides to take the class, I can't imagine them wanting to take the class but if by some chance they do, but do not do it quickly it could cause a delay.

Dick the way the CFPB website determins which 10 Counseling locations are closest to the Borrower is by "as the crow flies".  So I did a search for a Borrower in New London, CT and the second closest Counceling location the site was  in Long Island, NY.  The CFPB website listed the location as being 22.3 miles away, but that is if the Borrower takes the Ferry across the Long Island Sound, which round trip costs about $60.  If the Borrower drives there by car it is about a 200 mile drive.  Makes a lot of sense doesn't it?

Debbie they will all the information they would get at one of these Counseling Classes from a good Realtor and Loan Originator.  I say that because I have been a part of teaching Counceling Classes which are mandatory for DAP Loans.  All those Borrowers have to go through a mandatory 3 or 8 hour class depending on their circumstances, however, the highest default rate we have on Loans we service, is on loans with DAP's, so I have always questioned the value of the classes.

Dec 31, 2013 04:31 AM
John G. Johnston
John G. Johnston & Associates, LLC - Westcliffe, CO
An Exclusive Buyer's Agent ~ Westcliffe, CO

George  Thanks for the update.  I will check my area...and it ought to be interesting as we aren't close to anything!  Happy New Year

Jan 01, 2014 05:43 AM