Home Equity Conversion Mortgage (HECM) Counseling Standardization, Application for HECM Counselor Roster and Certificate of HECM Counseling
No material or nonsubstantive change to a currently approved collection
No
Regular
03/06/2025
Requested
Previously Approved
01/31/2027
01/31/2027
28,459
28,459
45,943
45,943
0
0
This PRA package provides reporting burden for individuals to apply to be placed on the HECM counselor roster. Individuals are required to successfully pass a standardized HECM exam and provide information collected on proposed form HUD 92904. HUD uses the information provided to determine the applicants' eligibility to be placed on the HECM counselor roster.
US Code:
12 USC 1708
Name of Law: National Housing Act
This collection is a reinstatement with changes of OMB 2502-0586, along with the request to transfer HUD Form 92904 to this collection. HUD 92904 is approved in PRA Collection OMB 2502-0524, Home Equity Conversion Mortgage (HECM) Insurance Application for Reverse Mortgages and Related Documents, which expires on 4/30/2024. At the time of this collection in 2015, OHC had approximately 850 HECM Counselors and over 7,000 HUD-approved Housing Counseling Agencies (HCAs). There are now 305 HECM Roster Counselors working at over 200 HUD Approved HCAs. This reduction has several causes. First, following the end of the Great Recession, a large amount of federal and state funding for Foreclosure Prevention ceased, resulting in many HCAs closing their businesses due to a lack of funding for the counseling services their agencies offered.
In the previous collection, Standardization of HECM Counseling was not a separate line item on the burden hours table. Also, in box number 12 on the OMB 83-I form, item “g,” which refers to state, local, or tribal government, was not previously captured and therefore was not a separate item on the #12 burden hour table.
HUD-92902, Certificate of HECM Counseling:
As noted, the HECM Final Rule was enacted on September 19, 2017. One of many significant and substantive changes to the HECM program was the defining of several terms of art for purposes of the HECM program, including, but not limited to, the terms “Borrower,” “Mortgagor,” and “Non-Borrowing Spouse.” In addition, the Final Rule makes clear who must receive HECM counseling. See 24 CFR sections 206.3 and 206.41. The updated Certificate does attempt to clarify who must be counseled as required under the Final Rule; however, the Certificate does not incorporate the correct HECM Program terminology (i.e., HECM Program terms as defined at 24 CFR 206.3) when referring to these individuals. For example, the Certificate refers to all prospective borrower(s) as “homeowner(s)” and to Non-Borrowing Spouses as “non-borrower spouse.” These latter terms, however, are clearly defined in 24 CFR Part 206, and the Certificate must be consistent with changes made by the Final Rule. Thus, we have revised the draft Certificate by incorporating the correct terminology when referring to prospective HECM borrower(s) and, when applicable, their non-borrowing spouse to make clear which parties are required to receive counseling. OHC has had many discussions with the Office of General Counsel regarding its concerns. As a result, OHC agreed to incorporate the changes outlined in the attached redline version of the draft Certificate.
HUD-92904, “Application for HECM Roster Counselor”
The PRA package includes OHC’s HUD-approved Application for HECM Roster (form HUD-92904) which has also been updated and for which OHC is seeking PRA reinstatement and approval. The Application requires that applicants certify they will comply with pertinent HUD and OHC requirements. In addition, HUD’s Office of General Counsel recommended that the language be revised to clarify the pertinent policies in the case of the relevant Handbooks (e.g., HUD Handbooks 7610.1, Rev-5, and 4235.1, as updated) OGC also recommended that OHC add a fourth bullet point that reads: “Debarment pursuant to 2 CFR Parts 180 and 2424.”
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form HUD 92904 Application for HECM Counselor Roster
Form Revision Chart Template HUD-92904.docx
OMB 83-C Form HUD-92904 signed.pdf
ML HECM Broker.doc
Application for HECM Counselor Roster