Can a lender provide the name and toll free number for a housing counseling agency not based in the client’s home state, but which provides phone counseling nationally?
Date Published: September 2015
No. HUD requires the provision of five counseling agencies within the client’s state, with one of those agencies being within reasonable driving distance. In addition, the lender is required to provide the telephone numbers for the three national networks approved by HUD to provide telephone counseling nationally: AARP, NFCC, and MMI. These requirements, and the use of these networks, are designed to prevent steering. The inclusion of an additional out-of-state phone counseling entity creates the appearance of steering. Counselors from this entity can provide telephone counseling nationally for clients referred through one of the three national networks listed above, but may not be included on the list of counseling agencies provided by the lender.