Comment on CFPB-2012-0034-0015

The Homeownership Preservation Foundation (HPF) congratulates CFPB for “proposing to include information about housing counselors to provide delinquent borrowers with additional resources to understand their loss mitigation options . . .” (Proposed § 1024.39(b)(vi)) Consumers are well-served by having the servicers include housing counselor contact information on the written notice. Housing counselors provide a critical consumer service during the housing crisis. HPF’s Homeowner’s Hope Hotline alone has served over 6 million callers and counseled over 1.5 million homeowners. Its counselors have helped consumers avoid foreclosure, resolve financial difficulties and engage effectively with the servicers. The tremendous volume of calls that the Hotline continues to serve shows the value that consumers place on having a knowledgeable, trustworthy and independent counseling resource available to help them. Research studies by the National Foreclosure Mitigation Counseling program (Urban Institute: 2011) and others provide substantive evidence that homewners have benefitted from counseling. In addition, housing counselors provide a bulwark against unscrupulous mortgage scam operators that seek to prey on unsuspecting homeowners. Beyond simply requiring that servicers include housing counselor contact information on the written notice, we encourage CFPB to require servicers to facilitate access to the housing counselor contacts if the consumer requests such assistance. Facilitating access would simply involve referring the consumer directly to one of the housing counselor contacts on the approved list by phone or email. We believe that this step would encourage consumers to take advantage of the benefits of independent, nonprofit, HUD-approved housing counseling and ease the consumer’s engagement with the servicer. The consumer would come to the servicer better prepared, more organized and with an advocate who can improve their chance of success.