If an agency is directly providing housing counseling as a requirement of a HUD program, does the housing counseling have to include all of the components that are in the definition of housing counseling at 24 CFR 5.100?
Date Published: June 2017
Yes, as of August 1, 2020, the Final Compliance Date, if an agency continues to directly provide housing counseling as a requirement of a HUD program, it must provide all of the components under the definition of housing counseling. The agency will be required to provide all of the services as described in the regulations at 24 CFR Part 5.100, including an intake; financial and housing affordability analysis; an action plan, except for reverse mortgage counseling; and a reasonable effort to have follow-up communication with the client when possible. Moreover, in order to provide housing counseling required under the HUD program, the agency will be required to be approved to participate in HUD’s housing counseling program and the housing counseling must be provided by HUD certified counselors.