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- HUD Programs Covered by the Housing Counselor Certification Requirements Final Rule
This page explains the HUD Housing Counselor Certification Requirements Final Rule as it applies to other HUD programs.
Read more background information about the Final Rule and learn how to begin the certification process.
View a flow chart showing how your HUD program may be covered by the Certification Final Rule.
Learn the steps and associated timeframes for becoming a HUD certified housing counselor.
Read the following sections in order to find out if your program is covered by the Final Rule.
Through the HUD Housing Counseling Program, HUD provides support to a nationwide network of housing counseling agencies to assist homeowners and renters in making responsible choices to address their unique housing needs. The HUD Housing Counseling program serves approximately 1 million clients each year. There were several major changes to the Housing Counseling Program through the Housing Counselor Certification Requirements Final Rule, which implemented the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including the following:
Many HUD-funded organizations are delivering housing counseling around the country. It is important first to understand what is considered housing counseling under the Final Rule, as well as who HUD certified housing counselors are, before applying the Final Rule to other covered HUD programs.
Housing Counseling is independent, expert advice customized to the needs of the consumer to address the consumer’s housing barriers and to help achieve their housing goals. It must include the following elements:
Types of housing counseling include homelessness assistance, rental assistance, pre-purchase/homebuying, non-delinquency post-purchase, resolving or preventing mortgage delinquency or default, reverse mortgage (HECM), and financial management/budgeting.
There are several services agencies may provide that are not considered housing counseling under the Housing Counselor Certification Requirements Final Rule. Some examples include:
NOTE: Some organizations may have staff that do not deliver housing counseling directly, and as a result do not need to be HUD certified.
There are two different requirements to become a HUD certified housing counselor.
To learn the steps for becoming a HUD certified housing counselor, view Everything You Need to Know about Certification.
Some organizations may have staff members who do not deliver housing counseling directly, and as a result, those staff members do not need to be HUD certified. For example, a city’s community development department may fund a housing counseling program and oversee a certified housing counseling staff member within the city. In this example, the community development manager does not have to be HUD certified since they are not directly providing housing counseling to clients.
HUD’s Housing Counselor Certification Requirements Final Rule covers approximately 26 other HUD programs. For purposes of applying HUD’s Housing Counselor Certification requirements, housing counseling “required under or provided in connection with any program administered by HUD” means one or more of the following:
If you are a grantee or sub-grantee of a HUD program covered by the final rule, you must read through the rest of the page and determine your options for compliance by the Final Compliance Date. The following flow chart and table provide a high-level overview of which programs may be covered by the final rule and how they could be affected.
HUD Program1 |
Housing Counseling2 Required by Specific HUD Program |
Housing Counseling if Funded by grantee |
Housing Counseling if Provided by grantee or subgrantee |
Housing Counseling if Referred by grantee or subgrantee |
---|---|---|---|---|
Community Planning and Development (CPD) Programs |
||||
Community Development Block Grant (CDBG), including CDBG-Disaster Recovery |
|
Yes |
Yes |
|
Continuum of Care (CoC) |
|
Yes |
Yes |
|
Emergency Solutions Grant (ESG) |
|
Yes |
Yes |
|
HOME Investment Partnerships |
Yes (homebuyer only) |
Yes |
Yes |
|
Housing Opportunities for Persons with AIDS (HOPWA) |
|
Yes |
Yes |
|
Neighborhood Stabilization (NSP) |
Yes (homebuyer) |
Yes |
Yes |
|
Housing Trust Fund |
Yes (homeownership only) |
Yes |
Yes |
|
Rural Housing Stability Assistance |
|
Yes |
|
|
Public and Indian Housing (PIH) Programs |
||||
Conversion of Distressed Public Housing to Tenant-Based Assistance |
|
Yes |
|
|
Displacement Due to Demolition and Disposition of Public Housing |
|
Yes |
|
|
Housing Choice Voucher |
|
|
Yes |
|
Housing Choice Voucher Homeownership Option |
Yes |
|
|
|
Family Self Sufficiency (FSS) |
|
|
|
Yes |
Multifamily Housing Service Coordinators |
|
|
|
Yes |
Native Hawaiian Housing Block Grant (NHHBG) |
|
Yes |
|
|
Resident Opportunities and Self Sufficiency (ROSS) |
|
|
|
Yes |
Public Housing Homeownership |
Optional |
|
|
|
Public Housing Operating Fund |
|
|
Yes |
|
Indian Housing Block Grant (IHBG) |
|
Yes3 |
Yes3 |
|
Indian Community Development Block Grant (ICDBG) |
|
Yes3 |
Yes3 |
|
1 If homeownership financial assistance provided through FHA Single Family Mortgage Insurance Program (for situations where housing counseling is required in connection with a specific FHA product, such as the Back to Work Extenuating Circumstances Initiative) or Home Equity Conversion Mortgage (HECM), the Certification Rule requirements are triggered.
2 Housing Counseling is defined in 24 CFR Part 5.100 – “Housing Counseling is independent, expert advice customized to the need of the consumer to address the consumer’s housing barriers and to help achieve their housing goals and must include the following processes: 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. The content and process of housing counseling must meet the standards outlined in 24 CFR part 214. Homeownership counseling and rental counseling are types of Housing Counseling.”
3 HUD is conducting tribal consultation to determine how to best implement the Section 106 statutory requirements as applied to the IHBG program and the ICDBG program and is soliciting Tribal feedback to determine how best to apply the housing counseling program and certification requirements in Section 106 to these programs.
Click on the green buttons below to understand how each HUD program may be affected by the Certification Final Rule.
Please Note: This page only includes active programs. Programs that are not included (e.g., Back to Work) may be added in the future if they become re-authorized.
Housing counseling is an eligible activity and may be funded under several different categories of activities in the CDBG program.
Depending on the program design and the intended beneficiaries, housing counseling may be an eligible activity:
Scenarios – How might this program be covered?
For more information view the CDBG FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be funded under several different categories of activities in the CDBG-DR program. In addition, in the aftermath of 2017 disasters, the Federal Register notices cover the requirement that CDBG-DR grantees must coordinate with HUD approved housing counseling agencies.
Depending on the program design and the intended beneficiaries, housing counseling may be an eligible activity:
Scenarios – How might this program be covered?
For more information view the CDBG-DR FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be funded under several different categories of activities in the CDBG-CV program. However, it is only eligible if provided to clients in need of assistance with their housing situation as a result of COVID-19. The counseling activity must be new or represent a quantifiable increase above the level of existing counseling services that have been provided in the 12 calendar months before the submission of the action plan.
Depending on the program design and the intended beneficiaries, housing counseling may be an eligible activity under the same conditions as typical CDBG funding:
Scenarios – How might this program be covered?
For more information view the CDBG-CV Toolkit: Eligible Uses.
Housing counseling is an eligible supportive service and may be funded under the CoC program.
Scenarios – How might this program be covered?
For more information view the CoC FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be funded under the ESG program. Please Note: ESG-CV also follows the same requirements as ESG. The following scenarios would also apply to ESG-CV.
Scenarios – How might this program be covered?
For more information view the ESG FAQs on Housing Counselor Certification.
Housing counseling is a requirement for HOME-assisted homebuyer activities including homebuyers receiving HOME-funded direct homebuyer assistance (i.e., down payment assistance) and homebuyers purchasing units developed with HOME funds. Housing counseling may also be funded as a part of a HOME homebuyer program. Finally, other types of housing counseling such as rental counseling for HOME-assisted tenants are eligible HOME-funded costs.
Scenarios – How might this program be covered?
Notice CPD-18-09: Requirements for HOME Homebuyer Program Policies and Procedures provides guidance on housing counseling requirements for HOME-assisted homebuyer, including the use of HUD-approved counselors and housing counseling agencies.
For more information view the HOME FAQs on Housing Counselor Certification.
Housing counseling on certain topics is an eligible activity as a HOME-ARP supportive service. Eligible topics include rental housing counseling, pre-purchase homebuying, and homeless services.
Post-purchase homeownership counseling (for example, resolving or preventing mortgage delinquency or home maintenance and financial management for homeowners), is not eligible under HOME-ARP.
Scenarios – How might this program be covered?
Notice CPD-21-10: Requirements for the Use of Funds in the HOME-American Rescue Plan Program provides guidance on eligibility of housing counseling for HOME-ARP programs, including the use of HUD-approved counselors and housing counseling agencies.
Housing counseling is an eligible activity and may be funded under the HOPWA program. Please Note: HOPWA-CV also follows the same requirements as HOPWA. The following scenarios would also apply to HOPWA-CV
Scenarios – How might this program be covered?
For more information view the HOPWA FAQs on Housing Counselor Certification.
Housing counseling is a requirement for HTF-assisted homebuyer activities including homebuyers receiving HTF-funded direct homebuyer assistance (i.e., down payment assistance) and homebuyers purchasing units developed with HTF funds. Housing counseling may also be funded as a part of an HTF homebuyer program. Finally, other types of housing counseling such as rental counseling for HTF-assisted tenants are eligible HTF-funded costs. While HTF funds cannot be used to fund stand-alone housing counseling programs, housing counseling is an eligible administrative cost as part of services to potential HTF-assisted owners, homeowners, and tenants.
Scenarios – How might this program be covered?
For more information view the HTF FAQs on Housing Counselor Certification.
Housing counseling is a requirement for NSP-assisted homebuyer activities including homebuyers receiving NSP-funded direct homebuyer assistance (i.e., down payment assistance) and homebuyers purchasing units developed with NSP funds. Housing counseling may also be funded as a part of a NSP homebuyer program.
Scenarios – How might this program be covered?
For more information view the FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be funded as a project cost in the Rural Housing Stability Assistance Program.
Scenarios – How might this program be covered?
For more information view the Rural Housing Stability Assistance Program FAQs on Housing Counselor Certification.
Housing counseling is a requirement for the Federal Housing Administration (FHA) Home Equity Conversion Mortgage Program (HECM).
Scenarios – How might this program be covered?
For more information view the HECM FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be a project cost requirement for the Conversion of Distressed Public Housing to Tenant-Based Assistance program.
Scenarios – How might this program be covered?
For more information view the Conversion of Distressed Public Housing to Tenant-Based Assistance FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be a project cost for the Displacement Due to Demolition and Disposition of Public Housing program.
Scenarios – How might this program be covered?
For more information view the Displacement Due to Demolition and Disposition of Public Housing FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be funded, and/or housing counseling referrals may be provided to residents under the Family Self Sufficiency (FSS) program. HUD’s Notice of Funding Availability (NOFA) allows FSS Coordinators to provide homeownership counseling.
Scenarios – How might this program be covered?
For more information view the FSS FAQs on Housing Counselor Certification.
Housing counseling is required by the Section 8 Housing Choice Voucher Homeownership Option program. However, Housing Choice Voucher program services that only provide housing information, or placement or referral services, (for example, mobility-related services), do not constitute housing counseling.
Scenarios – How might this program be covered?
For more information view the Housing Choice Voucher and Housing Choice Voucher Homeownership Option FAQs on Housing Counselor Certification.
Housing counseling referrals may be provided under the Multifamily Housing Service Coordinators Program.
Scenarios – How might this program be covered?
For more information view the Multifamily Housing Service Coordinators Program FAQs on Housing Counselor Certification.
Housing counseling is an eligible activity and may be funded under the Native Hawaiian Housing Block Grant (NHHBG) program.
Scenarios – How might this program be covered?
For more information view the Native Hawaiian Housing Block Grant Program FAQs on Housing Counselor Certification.
Housing counseling is an eligible funding activity and may be a project cost under the Public Housing Operating Fund. Public Housing Authorities (PHAs) are allowed to use their Public Housing Operating Funds to provide housing counseling to Public Housing residents, but PHAs are not required to provide housing counseling to Public Housing residents. Please note that routine administrative activities of the Public Housing Program (e.g., program eligibility determinations, intake, case management, property management, collection of rent) are not housing counseling.
Scenarios – How might this program be covered?
For more information view the Public Housing Operating Fund Program FAQs on Housing Counselor Certification.
Housing counseling may be a requirement for the Public Housing Resident Homeownership Program. Public Housing Agencies may elect to require residents involved in the program to participate in housing counseling.
Scenarios – How might this program be covered?
For more information view the Public Housing Resident Homeownership Program FAQs on Housing Counselor Certification.
Housing counseling referrals may be provided under the Resident Opportunity and Self-Sufficiency (ROSS) Program. HUD’s Notice of Funding Availability (NOFA), does not cover housing counseling activities provided by ROSS service coordinators.
Scenarios – How might this program be covered?
For more information view the Resident Opportunity and Self-Sufficiency Program FAQs on Housing Counselor Certification.
Please note that the certification requirement is undergoing tribal consultation before applying to these programs. OHC will update this page once the final rule has gone into effect for these programs.
Organizations that are not currently part of HUD’s Housing Counseling Program and have determined their program is covered by the Housing Counselor Certification Requirements Final Rule may choose to do one of the following:
Some organizations may choose to implement a short-term option followed by a longer-term solution. For example, a public housing authority may want to immediately find a partner to make sure they are covered for the Final Compliance Date of August 1, 2021. However, their long-term solution may be to participate directly in HUD’s Housing Counseling Program.
The following tools will assist you in partnering with organizations:
Not all organizations provide housing counseling directly and some do not need to have HUD certified housing counselors. However, organizations who fund/oversee housing counseling activities will need to ensure counseling services are provided by HUD certified housing counselors. Their subgrantees will either need to choose to find a partner or participate directly. For example, a state that receives HOME funds will need to cover the certification requirement in the state’s written agreement with the subgrantee. The written agreement will need to be modified to address this requirement.