A lender receives a complete application on May 4, 2026 for a covered closed-end federally related mortgage loan. It is neither a reverse mortgage nor a timeshare loan, and the application is not denied or withdrawn during the initial three-business-day period. No counseling list has been provided by a broker. When must the lender provide the required list of homeownership counseling organizations?
Correct Answer
B) The list is owed within 3 business days of the application
B. Provide the list within three business days after receiving the application. The list is an early application-stage disclosure. Its purpose is distinct from transaction-specific requirements to complete counseling. Scope and exceptions: A broker may supply the list, but the lender remains responsible for compliance. The list must use the specified sources and be obtained no earlier than 30 days before provision. HELOC timing has a separate alternative. Source: Section 1024.20(a)–(c) — https://www.consumerfinance.gov/rules-policy/regulations/1024/20/
Why This Is the Correct Answer
B. Provide the list within three business days after receiving the application. The list is an early application-stage disclosure. Its purpose is distinct from transaction-specific requirements to complete counseling. Scope and exceptions: A broker may supply the list, but the lender remains responsible for compliance. The list must use the specified sources and be obtained no earlier than 30 days before provision. HELOC timing has a separate alternative.
Why the Other Options Are Wrong
Option A: At closing, with the other closing documents
Waiting until closing is not the stated application-based deadline.
Option C: The list is owed within 7 business days of the application
Seven days is not this deadline.
Option D: The list is owed only where the loan is high-cost or a reverse mortgage
The list requirement is not limited to high-cost loans; reverse mortgages have a specific exemption here.
Exam Tip
Do not confuse providing a counselor list with requiring a counseling session.
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