Can a housing counselor double as a loan officer for the same non-profit organization?
Date Published: August 2016
This arrangement is permissible given adequate safeguards, including a full disclosure of the multiple roles played by the employee and a disclosure of relevant funding sources and relationships. Clients must be counseled on their alternatives and be made aware of their right to choose.
Additionally, when discussing specific loan products or features, at least one of the alternatives discussed by the counselor must be Federal Housing Administration (FHA) products or features, the Federal government’s safe and affordable options for home finance. For more information, see Chapter 3 of HUD Housing Counseling Handbook, 7610.1 REV-5.
The counselor/loan officer must not use the counseling program for private gain and must make an effort to remove any appearance of a conflict of interest. For example, a counselor/loan officer should receive a standard salary, not a commission for each loan originated or additional compensation based on the number of loans originated.