How can one prove with any degree of reliability that his/her/their income is not above a specified total? How does one go about proving a negative? How will this be consistently applied? Will there be a statement to be signed under penalties of perjury? Has no one in the counseling decision making process ever heard of the term “materiality?”

This is another good idea gone awry. To provide this information and document it with any degree of certainty will cost more than it is worth. The current counseling protocol and addendums show how little FHA is being influenced by anyone with any real financial credentials. While this idea sounds great, its outcome looks like the work product of financial neophytes.

Some maverick needs to stand up and shout: “Was counseling worth $125 to begin with?” For some it is worth far more but to most…. So how much per hour will counselors be permitted to charge? Will they be able to charge what the counseling agency deems it COULD be worth?

It is time to declare that counseling is now in danger of spinning out of control. With counseling executives making statements that apply to Standards when they are asked about Savers, declaring in the press that 20% of HECMs are not in compliance per industry “secret” documents, and most recently one discussing default information without providing meaningful statistical data upon which to evaluate the information she provided and no caveat that it was preliminary in nature, it seems counseling is going down a road that is feeding unnecessary opposition to HECMs. How is any of this being reigned in and if it supposedly is, where is the evidence? Maybe that is the negative which should be proved.