Client files often contain sensitive personal information. What guidance does HUD offer housing counseling agencies regarding client confidentiality and credit reports?
Date Published: November 2017
HUD expects housing counseling agencies to take confidentiality very seriously (24 CFR 214.316). The agency must hold all client information in strict confidence in a secure location. The agency may be subject to the penalties provided in the Fair Credit Reporting Act (14 U.S.C. 1681). Disclosure of information contained in credit reports can be made to clients depending on the terms of the contract between the agency and reporting credit bureau.
Please note that confidentiality also applies to HUD staff. Any information obtained by HUD staff, as part of a performance review, will be held in the strictest confidence. HUD staff will not include client Personally Identifiable Information (PII) on the 9910, review working papers, or in performance review reports. Additionally, if HUD staff has asked for client files related to a performance review the housing counseling agency must redact all PII from any files that are being sent either by mail, or electronically, unless a secure, encrypted method can be used for electronic transmission.