In November 2013, the CFPB published a tool to help consumers find local HUD-approved housing counselors. Now, the CFPB has published open source code to allow lenders to integrate the web-based tool into lender applications or websites. In the press release, the CFPB notes that the web-based tool can be used to find the 10 closest HUD-approved housing counselors to a consumer’s location and print or save the results. The CFPB encourages lenders to use the source code to build their own web-based tools for consumer use.
Also, the press release states that lenders can use the tool to comply with housing counseling requirements under Dodd-Frank. It is unclear whether using this tool would create a presumption of compliance or a safe harbor for lenders who utilize the source code to build the tool into their websites or applications. Further, there are issues regarding the manner in which the code can be altered and what display format is required for consumers to access the information. As noted previously, to comply with housing counselor requirements, a lender can either obtain a list through the CFPB’s website or independently generate its own list using the same HUD data used by the CFPB.
At the very least, lenders will be able to use the CFPB-developed code to integrate into their web-based platforms and give consumers access to required housing counselor information. The move could eventually decrease the amount of paper given to a mortgage applicant.