August 1, 2014

The HOEPA Homeownership Counseling Disclosure requirement, which informs borrowers they have the option to receive homeownership counseling from a HUD approved counseling agency, became effective for loans with an application dated on or after January 10, 2014.

The Consumer Financial Protection Bureau (CFPB) initially allowed for a temporary disclosure that directed borrowers to either the CFPB or HUD counseling agency website to locate a counseling agency in lieu of providing the borrowers a written list of agencies in their immediate area.

The CFPB has now mandated a written list be provided to borrowers; the temporary disclosure is no longer acceptable.

Loans submitted to REMN Wholesale on or after Monday, August 4, 2014 will require the new Homeownership Counseling Form, which will provide the written list of counseling agencies in the borrower’s immediate area, be included in the loan file.

REMN Wholesale will provide the new Counseling Form in the initial disclosure package sent to the borrower. Brokers are responsible to ensure the form is signed by the borrower(s) and returned to REMN Wholesale.

REMN Wholesale will not require the use of our specific form, however any form used must provide the information contained in the REMN Wholesale form and include HUD approved counseling agencies in the borrower’s immediate area. A sample form is attached for reference.

The rule and changes may be viewed at Consumer Financial Protection Bureau

If you have any questions, please contact your Account Executive.