With input from the HUD Issues Committee, NRMLA submitted comments to the Department of Housing and Urban Development this week that recommended the FNMA-1009 be replaced by the FNMA-1003 and that other changes be made to the HUD-92902 – Counseling Certificate, Form 92900-A and Form 92800.5B to make them less confusing to borrowers.
With the introduction of Financial Assessment and additional protections for non-borrowing spouses, “the FNMA-1009 for HECMs has become less suitable,” said NRMLA, “and, as a result, we recommend that HUD, instead of requiring mortgagees to use the FNMA-1009, permit mortgagees to use the FNMA-1003 for HECMs” that includes an addendum for the collection of additional borrower and property information.
As the HECM program has changed, the Counseling Certificate has not evolved to fully address program changes that impact counseling, added NRMLA. The association recommended that HUD add a check box for borrowers who receive counseling by video conference; that an additional signature line be added for a second POA/Guardian; that a signature line be added for non-borrowing owners; and that HUD increase the font size and revert to a two-page form to enhance its readability.
Read the full comments to see what other enhancements were recommended by visiting the Comment Letters section of NRMLAonline.org.