Once the counseling session is complete, the counselor should complete the client file, either
paper or electronic is acceptable. As stated in HUD's
... [Show More] Housing Counseling Handbook, all
counseling agencies must maintain a separate, confidential file for each client. The counselor
must ensure that the file contains all of the following conten
File number: A file number for the unique counseling interaction;
□ Financial Analysis/Budget: Evidence of analysis of the client's unique financial and credit
circumstances as they relate to the reverse mortgage;
□ Required Data: All required fields listed in the Interface Control Document (ICD) of the
Client Management System - details regarding these fields can be found at:
http://www.hud.gov/counselors/.
□ Activity Log: A record of the date, time, duration, and description of each interaction or
activity performed with, on behalf of, and by, the client;
□ Follow up: A record of all follow-up communication with the client must be documented.
This documentation must also include an account of all attempts to contact clients to conduct
follow-up sessions;
□ Counseling Participants: Listing of people other than the borrower(s) that attended the
reverse mortgage counseling session and a description of their relationship to the client(s);
□ Counseling Certificate: Signed and dated HECM counseling certificate; if the certificate
was not issued, the reason why it was withheld;
Agency Disclosure Statement: A copy of the disclosure statement provided to each client in
a face-to-face setting or a notation of the date that the disclosure statement was verbally or
electronically provided during telephone counseling. The disclosure statement identifies the
agency and explicitly describes the various types of services that it provides. It must clearly
state that the client is not obligated to receive, purchase, or use any other services offered by
the organization or its exclusive partners, in order to receive counseling services. For clients
receiving telephone counseling, the agency must verbally or electronically provide a
disclosure that meets these requirements.
□ Power of Attorney or other documents relating to legal competency, if applicable;
□ Total Annual Loan Cost (TALC): Assessment of the total annual costs of a reverse
mortgage including interest payments and other fees that require payment;
□ Amortization schedules for reverse mortgage loan options
Notation of other brochures or handouts on the reverse mortgage lending process /
procedures / timelines, reverse mortgage lenders, and/or alternatives to a reverse mortgage
provided to the client;
□ Documentation demonstrating that all required counseling content and information was
provided;
□ Statement about client's qualifications as a current or prospective borrower for a HECM or a
conventional reverse mortgage;
□ Pertinent Documents including copies (electronic or paper) of pertinent records or
correspondence received from the client or created on their behalf;
□ Termination documentation detailing when the housing counseling agency terminated
services. The housing counselor must notate the client's file with the date and
cause/explanation of termination. Client files must not remain open indefinitely;
□ Documentation of Results of counseling session(s);
□ Fees charged, if applicable; the amount paid through client fees and a copy of the receipt(s)
provided to the client;
□ HUD Grant Activity, if applicable, noting whether the activity was partially or fully funded
by a HUD housing counseling grant or sub-grant;
□ Discussion of Alternatives listing any service providers, product vendors, products, features,
services, or properties about which information was discussed with the client; and
□ Miscellaneous Information obtained during the intake and subsequent housing counseling
sessions not mentioned above. [Show Less]