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Housing Counseling Process Evaluation and Design of ... - HUD User

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This last point highlights the fact that not all organizations providing housing counseling services are<br />

<strong>HUD</strong>-approved. The most obvious exclusions are for-pr<strong>of</strong>it entities that provide these services,<br />

which are not eligible for <strong>HUD</strong> approval. A potentially significant source <strong>of</strong> counseling by for-pr<strong>of</strong>it<br />

organizations are banks themselves. A recent study <strong>of</strong> pre-purchase counseling on a sample <strong>of</strong> loans<br />

primarily originated by banks for credit under the CRA found that 45 percent <strong>of</strong> the borrowers<br />

receiving counseling received these services from their bank or lender. 15 In describing the evolution<br />

<strong>of</strong> pre-purchase counseling, Quercia <strong>and</strong> McCarthy (2000) noted that during the early 1990s<br />

counseling was commonly <strong>of</strong>fered by Countrywide Home Loans <strong>and</strong> GE Capital by telephone. There<br />

are also a variety <strong>of</strong> consumer credit counseling agencies that are for-pr<strong>of</strong>it <strong>and</strong> therefore would be<br />

excluded from <strong>HUD</strong> approval.<br />

Unfortunately, we do not have good estimates for the number <strong>of</strong> agencies <strong>of</strong>fering housing counseling<br />

services that are not <strong>HUD</strong>-approved. We interviewed several national organizations <strong>and</strong> SHFAs that<br />

fund counseling services but do not receive <strong>HUD</strong> funding in an attempt to underst<strong>and</strong> the housing<br />

counseling that takes place “outside the <strong>HUD</strong> network.” However, most <strong>of</strong> these intermediaries <strong>and</strong><br />

SHFAs reported that their affiliates are <strong>HUD</strong>-approved <strong>and</strong> do in fact receive <strong>HUD</strong> funding for<br />

housing counseling, either through other intermediaries or as individual <strong>HUD</strong> grantees. Based on our<br />

interviews, it seems that, at least at present, there are relatively few non-pr<strong>of</strong>it organizations providing<br />

housing counseling that are not <strong>HUD</strong>-approved.<br />

Exhibit 2-5 illustrates the number <strong>of</strong> <strong>HUD</strong>-approved housing counseling agencies as <strong>of</strong> March 2008,<br />

whether they are affiliated with a national or regional intermediary organization or SHFA, <strong>and</strong> the<br />

number <strong>of</strong> branch <strong>of</strong>fices that are associated with these different categories <strong>of</strong> agencies. As shown,<br />

there are a total <strong>of</strong> 1,813 <strong>HUD</strong>-approved counseling agencies, which collectively have 659 branch<br />

<strong>of</strong>fices, yielding a total <strong>of</strong> 2,472 counseling agency <strong>of</strong>fices throughout the country. Of these agencies,<br />

834 are LHCAs that are identified in <strong>HUD</strong>’s administrative data as being unaffiliated with a national<br />

or regional intermediary or a SHFA. These agencies are identified as having 529 branch locations in<br />

addition to their main <strong>of</strong>fice. Of the remaining agencies, 834 are identified as either being affiliated<br />

with a national or regional intermediary or are a branch <strong>of</strong> an intermediary. Collectively, these<br />

agencies have 125 branch <strong>of</strong>fices in addition to their main <strong>of</strong>fice. Finally, there are 145 agencies<br />

identified as affiliates <strong>of</strong> SHFAs, which collectively have 5 branch <strong>of</strong>fices.<br />

15<br />

Quercia <strong>and</strong> Spader, 2008.<br />

16<br />

Chapter 2. Overview <strong>of</strong> the <strong>Housing</strong> <strong>Counseling</strong> Industry

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