Can HECM counseling fees collected from clients, subject to the requirements of Mortgagee Letter 2008-09 and 2011-09, paid by the client or out of loan proceeds, be charged against the HUD Housing Counseling grant?
Date Published: September 2015
That portion of the actual cost of counseling that is not covered by the client fees assessed upfront or collected out of loan proceeds can be charged to the HUD grant. Clients who pay for counseling either upfront or from loan proceeds would be counted on the HUD form 9902. HUD form 9902 collects data regarding all client activity.