Home Equity Conversion
Mortgage (HECM) Counseling Standardization, Application for HECM
Counselor Roster and Certificate of HECM Counseling
Reinstatement with change of a previously approved collection
No
Regular
11/07/2023
Requested
Previously Approved
36 Months From Approved
28,459
0
45,943
0
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
2502-0586 30 day.pdf
OMB2502-0586_FormsRevisionChart92902rev.6.28.23.docx
ML HECM Broker.doc
Application for HECM Counselor Roster