National Housing Counseling Webinar - Providing Crucial Support

1. Welcome to the National Housing Counseling WebinarScheduled Start: 2:00 PM Eastern- We will be underway shortly – If you have any technical or audio issues – please review the Support for Technical Issues document by clicking on the Supporting Material Button located just below this screen All audio for this webinar is through your computer – there is no separate call-in number Please ensure that you are able to receive sound through your computer and that your speakers are un-muted

2. Important Things to Know If you have audio issues or the slides stop advancing – simply refresh or reload the page displaying the webinar • Question and Answer Format • Utilize “Ask a Question” button on your screen • Audio/Technology questions utilize the “Help” button • Questions will be answered at the end of the presentation • Supporting Material • A copy of this Power Point presentation • A PDF version of the presentation • Frequently Asked Questions related to technical issues (PDF)

3. Important Things to Know • Web Site Pop-ups During Presentation • Several helpful web sites will be provided to you for bookmarking during the presentation. You will need to disable your pop-up blocker to receive this information • Archive Version (POP-UP) http://www.hud.gov/offices/hsg/sfh/talk/parc/phiarch.cfm

4. Importance of Housing Counseling "These organizations are on the front lines of helping families who are desperate to remain in their homes." "Now, more than ever, it’s crucial that we support these agencies that are working with struggling families on a one-to-one basis to manage their money, navigate the home buying process, and secure their financial futures.“ HUD Secretary Shaun Donovan December 23, 2010

5. WOW!!Facts about HUD Housing Counseling Program* *Data as of 1/31/2011 -

6. Webinar Agenda • Introduction to Counseling Handbook • Delivery of Housing Counseling Services • Record Keeping Requirements • Reporting Requirements and Use of HUD Systems • Operational Requirements and HUD Monitoring • Acceptable Fees • Grant Writing Tips • Information Resources

7. Presenters David Gallian – Philadelphia HOC Eric Brown – Denver HOC Tracy Fields – Atlanta HOC Lorraine Griscavage-Frisbee – Santa Ana HOC Brian Siebenlist - Headquarters

8. Introduction to Housing Counseling Handbook 7610.1, Revision 5

9. HUD Handbook 7610.1, REV-5 Long anticipated revision released in May of 2010 Updated based on the Federal Register publication of the Housing Counseling Program Final Rule 24 CFR Part 214. Incorporates all policy changes related to housing counseling implemented through HUD Mortgagee Letters, Departmental data collection requirements and other Federal regulations issued since the publication of 7610.1 Revision 4

10. HUD Handbook 7610.1, REV-5 New Chapter dedicated entirely to reverse mortgage counseling; complete protocol included as an appendix This presentation outlines some major changes – please read 7610.1 REV-5 in its entirety to note program and policy updates

11. Delivery of Housing Counseling Services

12. Delivery of Housing Counseling Services • All participating agencies must operate under an approved housing counseling work plan • Explanation of the needs of the target population • How agency will address those needs • Agency resources available to meet the needs • Services to be provided • Identification of geographic area(s) to be served

13. Elements of a Counseling Work Plan Plan must also address: • Conflict of Interest/Disclosure • Alternative Settings/Format • Fee Schedules • Non-English Speaking or Limited English Proficiency Clients (LEP) • Plan may be periodically revised • Changes to the agency’s work plan must be approved by HUD prior to implementation

14. Basic Service Requirements In order for a client to be classified as counseled under HUD’s housing counseling program, the client must receive all of the following basic services: • Housing counseling on one of the HUD recognized topic areas • Discussion of at least four alternatives • Creation of an action plan (except for reverse mortgage clients) • Financial Analysis • Referrals • Follow-up every 60 days • Set up of client files – both electronic and paper • Termination of counseling when appropriate

15. HUD Approved Counseling Topics • Approved Housing Counseling Education and Outreach Topics: • Pre-purchase/Home Buying • Resolving or Preventing Mortgage Delinquency or Default • Non-Delinquency Post-Purchase • Rental • Reverse Mortgage • Homeless Assistance

16. Fair Housing and Other Civil Rights Requirements All participating agencies must identify impediments to Fair Housing and specify activities to Affirmatively Further Fair Housing Participating agencies should maintain records of activities to affirmatively further fair housing

17. Record Keeping Requirements

18. Record Keeping • Combination of paper and electronic files acceptable • Mandatory use of web-based client management systems(CMS) that interface with HUD • Agency must capture all mandatory data elements and complete all required data fields as defined by HUD Handbook 7610-1 Rev-5, 5-3 (A) • HUD must be able to access a complete electronic file for monitoring and other purposes • Files must be retained for at least three years from the date the file was terminated or the date the final grant invoice was paid by HUD

19. Maintenance of the Client File A separate file must be maintained for each client. File must contain the following : File Number Client Demographics Client Information Dates of activity Start and end times Counselor’s name Financial Analysis Action Plan Activity Log Follow-up Disclosure HUD Grant Activity Fees/Funding Sources Discussion of Alternatives Client Authorization Results Termination Client documents

20. Maintenance of Group Files • A separate file must be maintained for each group. Include the following in the file: • File Number • Data elements required for CMS such as each client demographics, name, address, etc. • Course Description • Instructors including housing counselor • Date, place and duration of each session • HUD Grant and/or fees • Disclosure

21. Use of Credit Reports • Counseling agencies can purchase credit reports for clients directly • May charge client if agency pays for it but can only charge client cost to agency • Credit reports from lenders for existing or proposed FHA mortgages • Available at no charge to agencies • Send written request to the lender

22. Confidentiality Requirements • Agency must hold all client information in strict confidence • Credit report is for client, HUD or HUD-approved mortgagees’ use only

23. Reporting Requirements and Use of HUD Systems

24. Quarterly Reporting All HUD Approved Agencies must maintain agency data in the HCS System:

25. HUD 9902 Reporting Requirements • Each agency must submit a quarterly HUD report online • MUST be filed online through agency’s CMS if interfaced to HUD systems • Through HUD’s automated Housing Counseling System (HCS) if CMS not interfaced to HUD system • Fiscal year is October 1 through September 30

26. HUD-9902 Reporting Requirements • Must report on the following: • Ethnicity of clients • Race of clients • Income levels – must know median income for target areas (http://www.huduser.org/datasets/il.html) • Number of clients receiving education • Number of clients counseled by purpose and results

27. Grant Reporting • Grantee’s reporting requirements will be specified in the Grant Agreement. • HUD GTR reviews the quarterly reports, which consist of a narrative, Form HUD-9902, budget and Logic Model (depending on grant agreement requirements for that year). • Reports will be rated as acceptable or unacceptable. • Deficient reports must be corrected by the agency and approved by the HUD GTR.

28. Grant Reporting • HUD Headquarters and Regional Homeownership Centers review the grant reports • Non-reporting or late reports may be cause for recapture of grant funds or HUD removal from the Housing Counseling Program

29. Operational Requirements and HUD Monitoring

30. Required Notifications • Participating agencies must notify HUD within 15 days when any of the following occurs: • The agency loses or changes its tax-exempt, non-profit status • The agency no longer complies with HUD, other Federal, local or state requirements • Address of the agency’s main office and the addresses of its branches and affiliates changes • Staff personnel responsible for the Housing Counseling Program, such as the housing counselors and management staff leave the agency • Telephone numbers of the main office, affiliates, and branches changes

31. Disclosure Requirements • Agencies that provide housing services in addition to their counseling services must disclose these services to HUD along with the following information: • Any business practices and/or partnerships that would constitute a conflict of interest • Description of the organizational structure and business practices that protect the client from inappropriate steering or influence • Agency’s written standard of ethics • Agency’s quality control plan for identifying, addressing or mitigating any conflicts of interest and complying with handbook requirements

32. Sub-Contracting Limitations • HUD Approved Housing Counseling agencies must not contract out housing counseling services • Employees should be W-2 Employees • Agencies are allowed to have volunteer counselors

33. Workload Requirements Workload: During each 12-month period, the participating agency must provide housing counseling to at least 30 clients Agencies that offer only housing counseling services limited to reverse mortgages, including home equity conversion mortgages (HECMs), are exempt from this requirement

34. Work Plan Requirements Housing Counseling Work Plan: The participating agency must implement its housing counseling work plan and demonstrate reasonable achievement of the outcome objectives approved by HUD Changes to a participating agency’s housing counseling work plan must be submitted to HUD for approval prior to implementation This includes proposed changes in services to be offered and geographic boundaries

35. Agency Requirements Reporting: the agency must submit to HUD complete, accurate, and timely activity reports Nondiscriminatory Practices: these laws prohibit discrimination because of race, color, religion, sex, national origin, disability, familial status or age Client Referrals from HUD and Other Participating Agencies: all clients who contact the agency as a result of these referrals must be served

36. Agency Requirements (cont.) RESPA: a participating agency or its interested parties must be in full compliance the Real Estate Settlement Procedures Act of 1974 Conflicts of Interest: the participating agency must comply with the conflict of interest provisions and are responsible for ensuring that their directors, employees, officers, volunteers and consultants understand and comply with these requirements

37. Agency Requirements (cont.)Alternative Information • If the counselor provides information about a specific service, program, feature or product, he/she must also provide information on relevant alternatives • FHA products, features or programs must be discussed as one of the available alternatives • At least three alternatives sources must be provided, if available

38. Agency Requirements (cont.)Staff and Supervision The agency must employ staff trained in housing counseling, and at least half the counselors must have at least six months experience in the job they will perform in the agency’s Housing Counseling program If less than one half of the counselors do not have the required experience this will be documented on the agency’s performance review report as a finding and documented in the agency’s official file maintained by HUD If the agency fails to maintain qualified staff to meet the program requirement, the agency can be terminated or placed on an inactive status until required staffing levels are met

39. Financial Capacity • Funding: The agency must maintain a level of funds that enables it to provide housing counseling to at least the required workload of clients every year whether or not the agency receives HUD funding • Audit: In accordance with 7610.1, Rev-5, paragraph 6-1 M, grant recipients and sub-grant recipientsthat: • expend $500,000 or more in a year in Federal awards must have a single or program-specific financial audit conducted for that year • do not expend $500,000 or more in a year in Federal awards, must have an independent audit every two years

40. Training Participating agencies are encouraged to send their housing counselors to formal training courses HUD may sponsor the training of counselors from participating agencies, and strive to do so fairly and equitably. Information on training is available at the Housing Counseling webpage

41. Expectations of Agency Staff • HUD expects staff of approved counseling agencies to be proficient in the following areas: • Counseling skills • Knowledge of other community resources • State and local real estate laws – working knowledge of current laws & ordinances • Financing options • Fair Housing laws

42. Performance Reviews HUD will conduct periodic on-site or desk performance reviews of all participating agencies

43. Performance Monitoring Failure to comply with any of HUD’s housing counseling record keeping and reporting requirements could result in consequences, which may include: • A delay in payment of vouchers • Forfeiture of all remaining funds in the grant • Future housing counseling grant applications being adversely rated • Ineligibility for HUD housing counseling training resources • Placement in inactive status or termination of the agency’s approved status

44. Consequences of Review HUD may change an agency’s status temporarily or an agency may contact HUD and state that they want to be inactive  • Re-Approval : 2 or 3 year approval • Conditional Status: 3 month approval to correct deficiencies • Inactive Status : 6 months to correct • Termination : Removal from the housing counseling program

45. Termination of Approval • Approval may be terminated by HUD at any time for any of the following reasons: • At the convenience of the government • Approved agency fails to maintain compliance with program requirements (example: agency fails to implement its approved counseling work plan) • Agency may withdraw from the program at any time • At which time the Certificate of Approval is returned to HUD

46. Performance Review Checklist • HUD reviews monitors the participating agency for compliance with: • Basic Program Requirements • Skills & Experience of Staff • Financial Capacity • Grant Management • Administrative Capacity/Program Practices

47. Performance Review Checklist (cont.) • Facilities • Conflict of Interest • Disclosure • Housing Counseling Work Plan • File Maintenance • Counseling Services • Other program compliance requirements

48. Performance Review Checklist (cont.) • On-site • Desk review • Remote Monitoring through agency CMS system

49. Most Common FindingsIndividual Files Client files not properly documented No action plan No budget analysis Group session attendance No evidence of follow-up with client No evidence of termination of client

50. Most Common FindingsGroup Files Not maintained Class dates missing Location of class missing No sign-in sheet No summary of course No listing of instructor(s)