NLIHC is a signatory to a letter from National Foreclosure Prevention and Neighborhood Stabilization Task Force in response to HUD’s proposed housing counseling rule (see Memo, 11/8). The letter was sent on December 4. NLIHC will also submit a separate comment letter in response to the proposed rule, and encourages readers to submit comments as well. All comments are due to HUD on December 12.
The proposed rule would implement changes to housing certification requirements made in the Dodd-Frank Act. The law requires that individual housing counselors, not just housing counseling agencies, be certified by HUD to provide housing counseling services in relation to both homeownership and rental housing programs.
Members of the Task Force commended HUD for formalizing the following changes to current housing counseling requirements:
- Setting a baseline level of competency for housing counselors as related to homeownership and rental options.
- Addressing the full continuum of housing options.
- Flexibility in certification exam preparation and training options.
Members of the Task Force suggested a revised approach to the proposed rule in five key ways:
- Minimizing certification costs to agencies and housing counselors.
- Clarifying the intent and focus of the core competency areas specified in the proposed rule.
- Developing a clear training and testing protocol.
- Clarifying the rule’s applicability to organizations that provide housing counseling related to HUD programs but do not receive housing counseling funds. Advocates are particularly concerned that as currently drafted the proposed rule requires all individuals who provide housing counseling services in relation to any HUD program, even if their organizations are not recipients of housing counseling dollars, will have to become HUD-certified housing counselors.
- Allowing the counselor certification process to begin before deciding whether or not to institute a continuing education requirement.
Read the full letter at: http://bit.ly/IAVSCj
Submit comments in response to the proposed rule at: http://1.usa.gov/1f71mjn