Housing Counseling FAQ

What information should a client file contain?

Date Published: March 2015

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A client file should contain the following:

  • All required fields listed in the Interface Control Document (ICD);
  • Evidence of financial and credit analysis, if applicable;
  • Activity Log - a narrative that contains the purpose and results of each visit, clearly identifying client need or problem, type of housing counseling provided, other activities performed on behalf of the client, and results of housing counseling;
  • Client’s Action Plan - an individual housing counseling action plan prepared by the housing counselor. The plan clearly identifies the client need or problem and outlines what the agency and the client will do in order to meet the client’s housing goal(s). A copy of the plan must be given to the client and maintained in the client’s file. An Action Plan is not required for reverse mortgage counseling;
  • A record of any follow-up with the client, as needed;
  • Copies (electronic or paper) of pertinent records or correspondence received from the client or created on their behalf;
  • The disclosure statement to be provided to each client in a face-to-face setting or a notation of the date that the disclosure statement was verbally provided during telephone counseling. The wording of the disclosure statement must be relevant to client;
  • Documentation of the termination of housing counseling with an explanation;
  • Cost of counseling - if applicable, the amount paid through client fees and a copy of the receipt provided to the client;
  • Supporting documentation for costs (e.g., payroll records);
  • An indication that the activity was partially or fully funded by a HUD housing counseling grant or sub-grant, when applicable;
  • A list of any service providers or product vendors about whom information was provided to the client;
  • Client authorization to order a credit report;
  • Other information obtained during the intake and subsequent housing counseling sessions not mentioned above; and
  • Additional documentation required for reverse mortgage client files that includes:
    • A list of other people other than the borrower(s) that attended the reverse mortgage counseling session and a description of their relationship to the client(s);
    • A signed and dated Home Equity Conversion Mortgage (HECM) counseling certificate;
    • Power of Attorney or other documents relating to legal competency, if applicable;
    • Annual Loan Cost Analysis;
    • Amortization schedules for reverse mortgage loan options; and
    • Notation of any brochures or handouts on the reverse mortgage lending process/procedures/timelines, reverse mortgage lenders, and/or alternatives to a reverse mortgage provided to client.

Tags: Housing Counseling Program Recordkeeping

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