Welcome to the National Housing Counseling Webinar Scheduled Start: 2: 00 PM Eastern - We will be underway shortly – 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 3/16/2018 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 1 1
Important Things to Know n n Question and Answer Format n Utilize “Ask a Question” button on your screen n Audio/Technology questions utilize the “Help” button n Questions will be answered at the end of the presentation Supporting Material n A copy of this Power Point presentation n A PDF version of the presentation n Frequently Asked Questions related to technical issues (PDF) If you have audio issues or the slides stop advancing – simply refresh or reload the page displaying the webinar 3/16/2018 2 2
Important Things to Know Web Site Pop-ups During Presentation n 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 n Archive Version (POP-UP) n http: //www. hud. gov/offices/hsg/sfh/talk/parc/phiarch. cfm 3/16/2018 3 3
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 3/16/2018 4 4
WOW!! Facts about HUD Housing Counseling Program* Approved National and Regional Intermediaries: 27 Affiliates and Sub-Grantees: 491 Locally Approved Housing Counseling Agencies 1, 011 MSOs and SHFAs 28 Clients Served in FY 2009 2. 98 million *Data as of 1/31/2011 3/16/2018 5 5
Webinar Agenda Introduction to Counseling Handbook n Delivery of Housing Counseling Services n Record Keeping Requirements n Reporting Requirements and Use of HUD Systems n Operational Requirements and HUD Monitoring n Acceptable Fees n Grant Writing Tips n Information Resources n 3/16/2018 6 6
Presenters David Gallian – Philadelphia HOC Eric Brown – Denver HOC Tracy Fields – Atlanta HOC Lorraine Griscavage-Frisbee – Santa Ana HOC Brian Siebenlist - Headquarters 3/16/2018 7 7
Introduction to Housing Counseling Handbook 7610. 1, Revision 5 3/16/2018 8 8
HUD Handbook 7610. 1, REV-5 n n n 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 3/16/2018 9 9
HUD Handbook 7610. 1, REV-5 n n 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 3/16/2018 10 10
Delivery of Housing Counseling Services 3/16/2018 11 11
Delivery of Housing Counseling Services n All participating agencies must operate under an approved housing counseling work plan n Explanation of the needs of the target population n How agency will address those needs n Agency resources available to meet the needs n Services to be provided n Identification of geographic area(s) to be served 3/16/2018 12 12
Elements of a Counseling Work Plan must also address: n Conflict of Interest/Disclosure n Alternative Settings/Format n Fee Schedules n Non-English Speaking or Limited English Proficiency Clients (LEP) n Plan may be periodically revised n Changes to the agency’s work plan must be approved by HUD prior to implementation 3/16/2018 13 13
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: n n n n 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 3/16/2018 14 14
HUD Approved Counseling Topics n Approved Housing Counseling Education and Outreach Topics: n Pre-purchase/Home Buying n Resolving or Preventing Mortgage Delinquency or Default n Non-Delinquency Post-Purchase n Rental n Reverse Mortgage n Homeless Assistance 3/16/2018 15 15
Fair Housing and Other Civil Rights Requirements All participating agencies must identify impediments to Fair Housing and specify activities to Affirmatively Further Fair Housing n Participating agencies should maintain records of activities to affirmatively further fair housing n 3/16/2018 16 16
Record Keeping Requirements 3/16/2018 17 17
Record Keeping n n n 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 3/16/2018 18 18
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 3/16/2018 Follow-up Disclosure HUD Grant Activity Fees/Funding Sources Discussion of Alternatives Client Authorization Results Termination Client documents 19 19
Maintenance of Group Files n A separate file must be maintained for each group. Include the following in the file: n File Number n Data elements required for CMS such as each client demographics, name, address, etc. n Course Description n Instructors including housing counselor n Date, place and duration of each session n HUD Grant and/or fees n Disclosure 3/16/2018 20 20
Use of Credit Reports Counseling agencies can purchase credit reports for clients directly n May charge client if agency pays for it but can only charge client cost to agency n Credit reports from lenders for existing or proposed FHA mortgages n Available at no charge to agencies n Send written request to the lender n 3/16/2018 21 21
Confidentiality Requirements Agency must hold all client information in strict confidence n Credit report is for client, HUD or HUDapproved mortgagees’ use only n 3/16/2018 22 22
Reporting Requirements and Use of HUD Systems 3/16/2018 23 23
Quarterly Reporting All HUD Approved Agencies must maintain agency data in the HCS System: Report Requirements Who must report? Validate All approved agencies Complete 9902 s - (cumulative) All approved agencies Logic Models – (cumulative) Agencies receiving HUD grants funds Budget - (quarterly and cumulative) Agencies receiving HUD grants funds Client List - (quarterly and cumulative) Agencies receiving HUD grants funds 3/16/2018 24 24
HUD 9902 Reporting Requirements Each agency must submit a quarterly HUD report online n MUST be filed online through agency’s CMS if interfaced to HUD systems n Through HUD’s automated Housing Counseling System (HCS) if CMS not interfaced to HUD system n Fiscal year is October 1 through September 30 n 3/16/2018 25 25
HUD-9902 Reporting Requirements n Must report on the following: n Ethnicity of clients n Race of clients n Income levels – must know median income for target areas (http: //www. huduser. org/datasets/il. html) n Number of clients receiving education n Number of clients counseled by purpose and results 3/16/2018 26 26
Grant Reporting n n 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. 3/16/2018 27 27
Grant Reporting HUD Headquarters and Regional Homeownership Centers review the grant reports n Non-reporting or late reports may be cause for recapture of grant funds or HUD removal from the Housing Counseling Program n 3/16/2018 28 28
Operational Requirements and HUD Monitoring 3/16/2018 29
Required Notifications n Participating agencies must notify HUD within 15 days when any of the following occurs: n The agency loses or changes its tax-exempt, non-profit status n The agency no longer complies with HUD, other Federal, local or state requirements n Address of the agency’s main office and the addresses of its branches and affiliates changes n Staff personnel responsible for the Housing Counseling Program, such as the housing counselors and management staff leave the agency n Telephone numbers of the main office, affiliates, and branches changes 3 0 3/16/2018 30
Disclosure Requirements n Agencies that provide housing services in addition to their counseling services must disclose these services to HUD along with the following information: n Any business practices and/or partnerships that would constitute a conflict of interest n Description of the organizational structure and business practices that protect the client from inappropriate steering or influence n Agency’s written standard of ethics n Agency’s quality control plan for identifying, addressing or mitigating any conflicts of interest and complying with handbook requirements 3/16/2018 31 31
Sub-Contracting Limitations HUD Approved Housing Counseling agencies must not contract out housing counseling services n Employees should be W-2 Employees n Agencies are allowed to have volunteer counselors n 3 2 3/16/2018 32
Workload Requirements Workload: During each 12 -month period, the participating agency must provide housing counseling to at least 30 clients n Agencies that offer only housing counseling services limited to reverse mortgages, including home equity conversion mortgages (HECMs), are exempt from this requirement n 3 3 3/16/2018 33
Work Plan Requirements n n n 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 3/16/2018 34 34
Agency Requirements Reporting: the agency must submit to HUD complete, accurate, and timely activity reports n Nondiscriminatory Practices: these laws prohibit discrimination because of race, color, religion, sex, national origin, disability, familial status or age n Client Referrals from HUD and Other Participating Agencies: all clients who contact the agency as a result of these referrals must be served n 3 5 3/16/2018 35
Agency Requirements (cont. ) n n 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 comply with these requirements 3 6 3/16/2018 36
Agency Requirements (cont. ) Alternative Information n If the counselor provides information about a specific service, program, feature or product, he/she must also provide information on relevant alternatives n FHA products, features or programs must be discussed as one of the available alternatives n At least three alternatives sources must be provided, if available 3 7 3/16/2018 37
Agency Requirements (cont. ) Staff and Supervision n 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 3/16/2018 38 38
Financial Capacity n n 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 recipients that: n expend $500, 000 or more in a year in Federal awards must have a single or program-specific financial audit conducted for that year n do not expend $500, 000 or more in a year in Federal awards, must have an independent audit every two years 3/16/2018 39 39
Training Participating agencies are encouraged to send their housing counselors to formal training courses n 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 n 4 0 3/16/2018 40
Expectations of Agency Staff n HUD expects staff of approved counseling agencies to be proficient in the following areas: n Counseling skills n Knowledge of other community resources n State and local real estate laws – working knowledge of current laws & ordinances n Financing options n Fair Housing laws 3/16/2018 41 41
Performance Reviews HUD will conduct periodic on-site or desk performance reviews of all participating agencies Review Element Focus Fee Structure Grant Files (Individual and Group) Facility Confidentiality of Records Counseling Areas Handicap Facility Signage Compliance with Program Guidelines Skills and Experience of Staff Financial and Administrative Capacity Work Plan and Client Surveys 3/16/2018 42 42
Performance Monitoring Failure to comply with any of HUD’s housing counseling record keeping and reporting requirements could result in consequences, which may include: n n n 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 4 3 3/16/2018 43
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 n Re-Approval : 2 or 3 year approval n Conditional Status: 3 month approval to correct deficiencies n Inactive Status : 6 months to correct n Termination : Removal from the housing counseling program 4 4 3/16/2018 44
Termination of Approval n n Approval may be terminated by HUD at any time for any of the following reasons: n At the convenience of the government n 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 n At which time the Certificate of Approval is returned to HUD 3/16/2018 45 45
Performance Review Checklist n HUD reviews monitors the participating agency for compliance with: n Basic Program Requirements n Skills & Experience of Staff n Financial Capacity n Grant Management n Administrative Capacity/Program Practices 3/16/2018 46 46
Performance Review Checklist (cont. ) n Facilities n Conflict of Interest n Disclosure n Housing Counseling Work Plan n File Maintenance n Counseling Services n Other program compliance requirements 3/16/2018 47 47
Performance Review Checklist (cont. ) n On-site n Desk review n Remote Monitoring through agency CMS system 3/16/2018 48 48
Most Common Findings Individual Files Client files not properly documented n No action plan n No budget analysis n Group session attendance n No evidence of follow-up with client n No evidence of termination of client n 3/16/2018 49 49
Most Common Findings Group Files Not maintained n Class dates missing n Location of class missing n No sign-in sheet n No summary of course n No listing of instructor(s) n 3/16/2018 50 50
Most Common Findings General n n n Conflict of Interest No disclosure form/inadequate disclosure HUD notified of staff/agency changes Agency does not have experienced staff No Agency plan or not following it (did not submit revisions to HUD) Facilities n Location not private n Not handicap accessible n Client files not secure 3/16/2018 51 51
Acceptable Fees 3/16/2018 52 52
Collection of Counseling Fees May charge reasonable and customary fees for housing education and counseling services as long as cost does not create a financial hardship on the client n The Fee Schedule must be posted in a prominent place and include the cost of Credit Reports, if applicable n 3/16/2018 53 53
Counseling Fees n n HUD approved counseling agencies should not charge clients needing homelessness counseling or default counseling HECM Counseling Fees: participating agencies may charge fees for reverse mortgage counseling services to clients and related parties that are able to afford them The fee must never exceed the actual cost of providing the service Moreover, HUD may further limit allowable charges via the issuance of Mortgagee Letters 3/16/2018 54 54
Counseling Fees n n n Debt Management Service Fees: If both debt management fees and housing counseling fees are charged to the same client, the agency must clearly differentiate between the two. Housing Counseling Fees: The fees should be reasonable and similar to what other housing counseling agencies charge in the area. Credit Reports: The agency may also be reimbursed from clients for the direct cost of obtaining copies of clients credit reports from credit reporting bureaus. n This cost should not cause a hardship for the client. In cases where the participating agency receives a discount for the cost of credit reports, this discount must be passed on to the client. 3/16/2018 55 55
Grant Writing Tips 3/16/2018 56 56
Basics of Grant Writing Step 1: Carefully read the General Section and Program Section of the NOFA n Identify the threshold factors that you will have to meet for your application to be reviewed 3/16/2018 57 57
Basics of Grant Writing Step 2: Make an Outline of the Requirements n As you read the NOFA note the must have items n Note the key elements in each rating factor n Highlight items that indicate: n YOU WILL RECEIVE HIGHER RATING POINTS IF YOU…” n …SCORING WILL BE BASED ON… 3/16/2018 58 58
Basics of Grant Writing Step 3: Make an Outline of Your Proposal n Organize using headings for ranking factors Step 4: Write a Concise Proposal n Don’t just recycle last year’s proposal n Use NOFA and Program language n Support all claims 3/16/2018 59 59
Rating Factor 1 Capacity of Applicant Knowledge and Experience n Grant and Program Requirements (i. e. prior agency performance – quarterly reports, performance reviews) n Management – Goals and Results n How was change managed? (adjustments) n Identify quantifiable goals and results n 3/16/2018 60 60
Common Problems – Rating Factor 1 Chart or narrative explanation of experience does not match resumes submitted n Relevant experience described too broadly n Need to describe the Online Client Management System n Failure to validate HCS n 3/16/2018 61 61
More Common Problems Rating Factor 1 n n n Specialized Training often not adequately described who provided training, date of training, subject of training Certifications – dates, who provided the certification, type of certificate, date certification expires, if applicable, often missing Management – Goals and Results – Many applications do not discuss how they manage change, nor do they explain why their goals were not met 3/16/2018 62 62
Rating Factor 2 Need/Extent of the Problem n n Needs Data Departmental Policy Priorities – Examples from past years: n Sustainability n Affirmatively Furthering Fair Housing n Capacity Building and Knowledge Sharing n Using Housing as a Platform for Improving Other Outcomes 3/16/2018 63 63
Common Problems Rating Factor 2 Outdated demographic information n No reference to Consolidated Plan (if applicable), Analysis of Impediments or similar report n No reference to needs of disabled population n Inadequate explanation of needs to support proposed work plan n 3/16/2018 64 64
Rating Factor 3 Soundness of Approach / Scope of Housing Counseling Services Historical Performance n Quality and Complexity of Services n Average Hours per service n Group vs. One-on-one n Description of Marketing and Outreach Efforts n Capacity of Organization (Number of Clients that were served) 3/16/2018 65 65
Rating Factor 3 Projected Performance n Quality and Complexity of Services n Description of Types of Counseling and Education Services Provided n Affirmatively Further Fair Housing n Level of Services (Topics covered within each service area) n Budget Explanation (Explanation of how the requested grant funds will be used) n Cost Per Client 3/16/2018 66 66
Rating Factor 3 Projected Performance n Coordination n List Community Partners n Coverage/Efficient Use of Resources n Description of Partnerships n Complementing Other HUD Programs n Conflict of Interest n Sufficient Staff n Percentage of Grant Spend Spent on Salaries of Counselors and Fringe Benefits 3/16/2018 67 67
Common Problems - Rating Factor 3 Inadequate description of historical activities n Applicants hours per service were below average n Didn’t provide types of counseling n Didn’t provide hours per counseling type n Didn’t provide number of clients per counseling type n Low percentage of one-on-one counseling 3/16/2018 68 68
Common Problems - Rating Factor 3 n n Inadequate description of proposed activities n High cost per client with no justification Logic Model Outputs in Factor 5 must correlate to number of projected number of clients to be served in Rating Factor 3 narrative Need specifics in narrative about coordination, partnering, and internal products No Conflict of Interest Policy or Disclosure Form 3/16/2018 69 69
Rating Factor 4 Leveraging Resources Other funding (in addition to HUD Grant) available to operate proposed housing counseling program n Letters of commitment (with specific amount for Housing Counseling) n MOU (Memo of Understanding) n Contract including amount, date, service n Applicant Matching Funds and Program Income 3/16/2018 70 70
Common Problems - Rating Factor 4 n n n No leveraging letters submitted Letters do not state funds are for housing counseling No specific amount designated for housing counseling functions Dates in letters do not correspond with grant period stated in NOFA instructions Leveraged funding exceeds total housing counseling budget on Form 424 3/16/2018 71 71
Rating Factor 5 Achieving Results/Program Evaluation n Program Logic Model n Outputs/Services need to correspond to narrative for projected performance in Rating Factor 3 n Outcomes in Logic Model must correspond to Outputs Projections must be Consistent with narrative outcomes and outputs Evaluation Tools 3/16/2018 72 72
Common Problems - Rating Factor 5 Unable to determine projected number of clients because narrative and Logic Model do not match n Logic Model not submitted – Incurable deficiency n Agency did not address what adjustments will be made if goals are not being met n 3/16/2018 73 73
Common Problems with Applications n n Agency not properly registered with Grants. gov Application not submitted timely through Grants. gov n Application must be received AND validated by deadline Attachments not submitted in proper format n Microsoft Word, Microsoft Excel, Adobe (. pdf) format Form HUD-2990 (Certification of RC/EZ/EC needs to be signed by the appropriate RC/EZ/EC contact person) n RC/EZ/EC must be designated on www. hud. gov n Form can not be signed by applicant 3/16/2018 74 74
Information Resources 3/16/2018 75 75
Helpful Web Sites for Counselors Housing Counselor HUD Web Page (Pop-Up) http: //www. hud. gov/offices/hsg/sfh/hcc_home. cfm Housing Counseling Handbook (Pop-Up) http: //www. hud. gov/offices/adm/hudclips/handbooks/hs gh/7610. 1/index. cfm 3/16/2018 76 76
Where to Get More Information FHA Frequently Asked Questions (Pop-Up) n http: //www. fhaoutreach. gov/FHAFAQ/ n A web site containing almost 1, 300 questions and answers about FHA programs, underwriting and processing. n Searchable by key word and category. 3/16/2018 77 77
Where to Get More Information FHA Resource Center TELEPHONE 1 -800 -CALLFHA (1 -800 -225 -5342) Available Monday-Friday from 8: 00 – 8: 00 (Eastern Time) E-MAIL ANSWERS@HUD. GOV 3/16/2018 Available 24 hours a day – 7 days a week! 78 78
Where to Get More Information www. hud. gov/fha The main web site for the latest news on FHA programs http: //www. hud. gov/offices/adm/hudclips/index. cfm HUDCLIPS - the source for FHA policy documents handbooks, mortgagee letters and notices 3/16/2018 79 79
Coming Up Now n Training evaluation (Pop-Up) n Questions and Answer Session 3/16/2018 80 80
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