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Housing Counseling FAQ

What are some of the most common file and recordkeeping problems HUD reviewers identify during performance reviews?

Date Published: March 2015

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Here is a list of some common problems identified:

  • Counseling type (client problem or need) not identified or documented;
  • Client name and/or address is not complete;
  • Housing counseling action plan is missing (not applicable to reverse mortgage counseling files);
  • The funding source for the counseling is not identified;
  • Documents that demonstrate the counselor discussed financial status and evaluated income, debt, financial obligations, etc. to determine appropriate course of action for the client are missing;
  • No evidence that follow-up activities were performed by the counselor;
  • Termination of counseling - date and reason - not documented;
  • No evidence that the agency’s disclosure statement was provided to the client; and
  • In reverse mortgage client files, no evidence that alternatives were discussed.

Tags: Housing Counseling Program Recordkeeping