Agencies participating in HUD’s Housing Counseling Program may charge a fee for HECM counseling services as long as the cost is reasonable and customary, does not create a financial hardship for the client, and meets all other regulatory requirements.
The housing counseling agency must make a determination about a client’s ability to pay, which should include factors, including, but not limited to, income and debt obligations.
Agencies must inform clients of the fee structure in advance of providing services. A client must not be turned away because of an inability to pay. The housing counseling agency may not withhold counseling or the Certificate of HECM Counseling based on failure to pay.
A HECM counseling fee of $125 per counseling session constitutes a reasonable and customary fee, and does not exceed a level so as to be generally commensurate with the education and counseling services that are typically provided. Agencies may not impose fees upon clients for the same portion of or for an entire service that is already funded with HUD Housing Counseling grant funds. Should the cost of providing HECM counseling be less than $125, the maximum amount an agency may charge is the actual cost of counseling. All agencies charging fees for HECM counseling must document, in the client file, the actual cost of providing counseling.
Mortgagee Letters 09-10 and 08-12 are available at https://www.hud.gov/program_offices/administration/hudclips/letters/mortgagee