It is not up to GAO to defend HUD. It is the job of GAO to test a premise and report the findings.

The premise GAO tested is that HUD counselors are meeting HUD minimum requirements during counseling sessions. The result was mixed except that no counselor presented all of the required topics.

While it is correct to say that 15 samples is not representative of a population of well over 120,000 counseling sessions that are expected to occur in this year alone, it is fair is to say that 15 errors in a quantitatively measured compliance test is horrible even if the sample size had been more reasonable and representative. Yes, my opinion assumes the selection process was reasonably unbiased and those evaluating their counseling experience were fair, honest, and reasonable in their findings. But let’s not underplay these results; they will not simply go away.

When a consumer is paying $90 to $125 for one-half to one hour’s worth of counselor’s time (and at times far less), it is disheartening to hear that some want the TALC portion of the counseling exam removed because it is too hard and it is somehow just a lender issue. When properly understood and explained, this form brings to light what other forms do not. For example and despite its questionable term and credit line payout assumptions, the TALC schedule clearly demonstrates that the percentage cost of a reverse mortgage should drop over time. It also demonstrates that seniors should generally avoid this loan if the entire term of the loan is expected to be less than 2 years. In most cases it also demonstrates how no (or at times low) appreciation impacts the actual percentage cost to the borrower and the benefit of a non-recourse debt.

In conclusion, counselors need to do better and increase their knowledge and skills. HUD needs to find a way to monitor counseling sessions through proper sampling techniques. Too many originators find the current counseling system far too comfortable since it does not properly challenge their competence. To have counselors forced to do better is healthier not only for counselors but also for prospects, borrowers, originators, lenders, FHA, the HECM program, and the American taxpayer. The best news is that these findings help HUD understand where counseling needs improvement and if HUD continues to test the counseling process and evaluate those findings, the whole HECM experience can become an even stronger and more reliable system for obtaining the information seniors need to make their HECM decision. The vast majority of us have done well to date but the GAO study proves that we all can do better.