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HUD Programs Covered by the Housing Counseling Certification Requirements Final Rule

This page explains the HUD Housing Counseling Certification Requirements Final Rule as it applies to other HUD programs.

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Everything You Need to Know about Certification

Read more background information about the Final Rule and learn how to begin the certification process.

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Flow Chart: CPD and PIH Programs Covered by the Final Rule

View a flow chart showing how your HUD program may be covered by the Certification Final Rule.

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Timeline to Become a HUD Certified Housing Counselor

Learn the steps and associated timeframes for becoming a HUD certified housing counselor.

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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 Counseling Certification Requirements Final Rule, which implemented the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including the following:

  • Establishment of the Office of Housing Counseling
  • Standardization of housing counseling procedures
  • Requirements to use HUD certified housing counselors under HUD programs in Community Planning and Development (CPD), Public and Indian Housing (PIH) and FHA Single Family Mortgage Insurance Program

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.

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What is housing counseling (24 CFR § 5.100)?

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:

  1. Intake
  2. Client budget
  3. Financial and housing affordability analysis
  4. A client action plan
  5. A reasonable effort to follow-up with client

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.

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What is not housing counseling?

There are several services agencies may provide that are not considered housing counseling under the Housing Counseling Certification Requirements Final Rule. Some examples include:

  • Services that provide only housing information or placement/referral services
  • Routine administrative activities (e.g., program eligibility determinations, intake, case management)
  • Case management that provides housing services as incidental to a larger case management and does not fund housing counseling
  • Fair housing advice and advocacy (e.g., processing complaints and filing claims)
  • Group education including online education without individualized housing counseling services

NOTE: Some organizations may have staff that do not deliver housing counseling directly, and as a result do not need to be HUD certified.

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What does it mean to be HUD certified?

There are two different requirements to become a HUD certified housing counselor.

What is a HUD Certified Housing Counselor? A counselor who passed the HUD Housing Counselor Certification Exam + Works for a HUD-Approved Agency = 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 Counseling 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:

  • Housing counseling required by statute, regulation, Notice of Funding Availability, or otherwise required by HUD
  • Housing counseling that is funded under a HUD program
  • Housing counseling that is required by a grantee or subgrantee of a HUD program as a condition of receiving assistance under the HUD program
  • Housing counseling to which a family assisted under a HUD program is referred by a grantee or subgrantee of the HUD program

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.

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.

Office of Community Planning and Development (CPD) Programs

FHA Single Family Mortgage Insurance Program

Public and Indian Housing (PIH) Programs

Indian CDBG and Indian Housing Block Grant (IHBG) Programs

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.

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Options for Compliance

Organizations that are not currently part of HUD’s Housing Counseling Program and have determined their program is covered by the Housing Counseling Certification Requirements Final Rule may choose to do one of the following:

  1. Find a Partner: Partner with existing HCAs to deliver services and/or modify their programs to comply with the Final Rule:
    • To partner with an existing approved HCA, search for approved HCAs in your area. Select your state and review the list of approved HCAs. You can specify agency name, specific city, ZIP, counseling service, language, or designation: Colonias, Faith-Based, and Migrant Workers.
    • To find a partner with HUD certified housing counselors, be sure to search for HCAs with certified counselors in your area. Select your state and “certified” as the counseling type.
  2. Participate Directly: The options and process for approval are best viewed in the HUD Approval Process graphic and the HUD Approval page. If your organization decides to join the HUD Housing Counseling Program, there are two ways to participate.
    1. Apply directly to HUD as one of the following:
      • Local housing counseling agency (LHCA) – Provides housing counseling and education services directly through one location or a main office with one or more branch offices, in no more than two contiguous states. An exception can be made for an LHCA that serves a single metropolitan area covering more than two contiguous states.
      • National Intermediary – Provides, in multiple regions of the United States, (1) housing counseling services through its branches, subgrantees, and affiliates, which are physically located in nine or more states, and (2) training, technical assistance, oversight, and pass-through funding to its network of branches, subgrantees, and affiliates.
      • Regional Intermediary – Provides, in a generally recognized region within the United States, such as the Southwest, Mid-Atlantic, New England, (1) housing counseling services through its branches, sub-grantees, and/or affiliates, which are physically located in eight or fewer states, and (2) training, technical assistance, oversight, and pass-through funding to its network of branches, subgrantees, and/or affiliates.
      • Multi-state organization (MSO) – Provides housing counseling and education services through a main office and branches in two or more states. All branches operate and are identified under main office tax ID number and provide training, technical assistance, oversight, and pass-through funding to its branches.
      • State Housing Finance Agency (SHFA) – Any public body, agency, or instrumentality created by a specific act of a state legislature empowered to finance activities designed to provide housing and related facilities through land acquisition, construction, or rehabilitation throughout the entire state.
    2. Apply through a HUD-approved Intermediary or SHFA. Intermediaries and SHFAs provide LHCAs with critical supportive services, including training, tools, templates, pass-through funding, and technical assistance. They also monitor their networks to ensure services meet program standards and effectively meet the needs of their clients.
  3. End Delivery of Housing Counseling: Organizations that do not comply by the Final Compliance Date of August 1, 2021 may not continue their housing counseling activities if counseling activities are not provided by HUD certified housing counselors. Note: HUD strongly recommends organizations partner with an existing HCA, at a minimum, rather than exercising this option. Please note for any HUD activity that requires housing counseling (e.g., HOME homebuyer), the organization would have to stop funding the activity if it cannot provide HUD certified housing counseling either by partnering with a HUD-approved agency or by becoming a HUD-approved HCA.

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:

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Pass Through 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.

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