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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Subcommittee on Insurance, Housing and Community 
Opportunity, Committee on Financial Services, House of Representatives: 

For Release on Delivery: 
Expected at 2:00 p.m. EDT:
Wednesday, September 14, 2011: 

Homeownership Counseling: 

Although Research Suggests Some Benefits, Implementation and 
Evaluation Challenges Exist: 

Statement of Alicia Puente Cackley, Director: 
Financial Markets and Community Investment: 

GAO-11-925T: 

GAO Highlights: 

Highlights of GAO-11-925T, a testimony before the Subcommittee on 
Insurance, Housing and Community Opportunity, Committee on Financial 
Services, House of Representatives. 

Why GAO Did This Study: 

Homeownership counseling can help consumers learn about buying a home 
and give them tools to deal with setbacks that could keep them from 
making timely mortgage payments. The Department of Housing and Urban 
Development (HUD) approves and provides grants to housing counseling 
agencies and has also implemented a requirement that borrowers seeking 
federally insured reverse mortgages through the Home Equity Conversion 
Mortgage (HECM) program receive counseling before taking out a HECM. 
The U.S. Department of the Treasury (Treasury) has also implemented a 
counseling requirement as part of its mortgage modification efforts 
under the Home Affordable Modification Program (HAMP). This statement 
discusses (1) what research suggests about the effectiveness of 
homeownership counseling and the challenges of conducting such 
research, (2) shortcomings that prior GAO work found in federal 
agencies’ implementation of homeownership counseling requirements, and 
(3) the status of efforts to establish an Office of Housing Counseling 
within HUD. 

In preparing this statement, GAO relied on its past work on 
homeownership counseling, including a review of research and 
interviews with federal agency staff on implementing and evaluating 
counseling programs. 

GAO has made recommendations to HUD and Treasury to improve oversight 
and evaluation of their homeownership counseling requirements. HUD 
implemented the recommendations, while Treasury said that 
implementation would be too burdensome. 

What GAO Found: 

The body of literature on homeownership counseling does not provide 
conclusive findings on the impact of all types of counseling. Recent 
research on foreclosure mitigation counseling—-which helps financially 
distressed homeowners who are delinquent on payments-—suggests that it 
can help homeowners avoid foreclosure and prevent them from lapsing 
back into default. Findings on pre-purchase counseling-—which helps 
potential homebuyers learn about buying a home and explains the 
financial responsibilities of homeownership-—are less clear. One study 
concluded that such counseling lowered the default rate for new 
homeowners, but other studies showed no effect. Efforts to measure the 
impact of homeownership counseling have been hampered by a lack of 
data, as well as by challenges in designing studies and creating 
effective performance measures. Further studies are under way at HUD 
and Fannie Mae that are designed to overcome some of these limitations. 

Prior GAO work identified shortcomings in the implementation of 
homeownership counseling requirements for two federal programs. A 2009 
study of the HECM program found that HUD’s internal controls did not 
ensure that counselors were complying with program requirements. HUD 
later made improvements to the HECM program to address GAO’s 
recommendations. Another GAO study from 2009 found that Treasury did 
not effectively track whether borrowers required to seek counseling 
under HAMP actually received it or whether counseling reduced the rate 
of redefaults. Treasury officials said that they had not implemented a 
monitoring process because it would be too burdensome for Treasury and 
mortgage servicers. They also did not plan to assess the effectiveness 
of counseling in limiting redefaults, in part because they believed 
that the benefits of counseling on the performance of borrowers with 
high debt burdens were well documented. GAO continues to believe that 
monitoring and assessment would provide valuable information on 
whether the counseling requirement is having its intended effect. 

HUD is establishing a new Office of Housing Counseling, as required by 
the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-
Frank Act). According to HUD, the agency is developing a 
reorganization plan but is unable to estimate when it will be 
submitted to Congress. Budget constraints could affect the new 
counseling office. Although the Dodd-Frank Act authorized $45 million 
per year through fiscal year 2012 for the operations of the new 
office, HUD has not received appropriations for this purpose. In 
addition, appropriations for fiscal year 2011 eliminated HUD’s housing 
counseling assistance funds, which are primarily grant funds for 
approved counseling agencies. 

View [hyperlink, http://www.gao.gov/products/GAO-11-925T]. For more 
information, contact Alicia Puente Cackley at (202) 512-8678 or 
cackleya@gao.gov. 

[End of section] 

Chairman Biggert, Ranking Member Gutierrez, and Members of the 
Subcommittee: 

I am pleased to be here to participate in today's hearing on housing 
counseling. As you know, housing counseling can help consumers 
determine whether and when to purchase a home, how to manage a 
mortgage, and how to deal with setbacks that could limit their ability 
to make timely mortgage payments. This subcommittee's focus on such 
assistance is critical, given that the number of homes in foreclosure 
and of homeowners in financial distress remains at historically high 
levels. In the second quarter of 2011, more than 3.4 million home 
mortgages were 90 or more days delinquent or in the foreclosure 
process, and estimates indicate that more than one in five mortgage 
borrowers owe more on their mortgages than their homes are worth. The 
Department of Housing and Urban Development (HUD) approves and 
provides grants to housing counseling agencies. It has also 
implemented a requirement that federally insured reverse mortgage 
borrowers participating in the Home Equity Conversion Mortgage (HECM) 
program receive counseling before getting their mortgages.[Footnote 1] 
The U.S. Department of the Treasury (Treasury) has also implemented a 
counseling requirement as part of its mortgage modification efforts 
under the Home Affordable Modification Program (HAMP).[Footnote 2] 

My statement today is based on recent work we have conducted related 
to housing counseling and will discuss (1) what research suggests 
about the effectiveness of homeownership counseling and the challenges 
of conducting such research, (2) shortcomings that our prior work 
found in federal agencies' implementation of homeownership counseling 
requirements, and (3) the status of efforts to establish an Office of 
Housing Counseling within HUD.[Footnote 3] 

In preparing the reports on which this testimony is based, we reviewed 
research and conducted interviews with appropriate researchers and 
agency staff on the impact of homeownership education and counseling, 
HUD's controls over reverse mortgage counseling, HUD's plans for 
creating an Office of Housing Counseling, Treasury's processes and 
documentation for the Financial Education and Counseling Pilot 
Program, and Treasury's implementation of a counseling requirement 
under HAMP.[Footnote 4] We also interviewed selected homeownership 
counseling providers and mortgage market researchers as well as HUD 
and Treasury officials. 

We performed the work for the reports underlying this testimony as 
part of our ongoing oversight responsibilities from April 2008 through 
July 2011. We performed our work in accordance with generally accepted 
government auditing standards. Those standards require that we plan 
and perform the audit to obtain sufficient, appropriate evidence to 
provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence we obtained 
provides a reasonable basis for our findings and conclusions based on 
our audit objectives. 

Background: 

Homeownership counseling refers to pre-purchase and post-purchase 
counseling of homeowners and is a subset of housing counseling, which 
can also include assistance to renters and homeless populations. 
Prepurchase counseling generally refers to counseling for potential 
homebuyers to learn about whether and when to buy a home and how to 
manage a mortgage, budget for repairs, and fulfill other financial 
responsibilities of being a homeowner. Post-purchase counseling 
primarily refers to foreclosure mitigation counseling, which focuses 
on helping financially distressed homeowners avoid foreclosure by 
working with lenders to cure mortgage delinquency but can also include 
subjects such as home maintenance. Counseling can take place in 
person, over the telephone, via a self-study computer module, or with 
a workbook, and can vary in length from a single session to several 
sessions spread over a period of weeks or months. 

The federal government funds homeownership counseling through a number 
of programs at HUD, Treasury, the Department of Defense, and the 
Department of Veterans Affairs. Congress has also provided targeted 
support for foreclosure mitigation counseling. For example, in recent 
years, Congress has appropriated funds to the National Foreclosure 
Mitigation Counseling (NFMC) Program, which was designed to rapidly 
expand the availability of foreclosure mitigation counseling. NFMC is 
administered by NeighborWorks® America, a government-chartered, 
nonprofit corporation with a national network of affiliated 
organizations, which competitively distributes NFMC funds to other 
recipients. 

Findings from the Limited Research Available on Homeownership 
Counseling Are Mixed: 

The limited body of literature on homeownership counseling does not 
provide conclusive findings on the impact of all types of 
homeownership counseling. Some studies suggest that foreclosure 
mitigation counseling can be effective in improving mortgage outcomes 
(e.g., remaining current on mortgage payments versus defaulting or 
losing the home to foreclosure). However, findings on prepurchase 
counseling are less clear. Research on homeownership counseling is 
limited in part because of data limitations and other challenges. 

Although Research on Foreclosure Mitigation Counseling Suggests 
Benefits, Results on Other Types of Counseling Are Mixed: 

Recent research on foreclosure mitigation counseling suggests that it 
can help struggling mortgage borrowers avoid foreclosure and prevent 
them from lapsing back into default, especially if the counseling 
occurs early in the foreclosure process. A 2010 evaluation of NFMC 
found that homeowners who received counseling under the program were 
more likely to receive loan modifications and remain current on their 
mortgages after counseling, compared with a group of non-NFMC 
borrowers with similar observable characteristics. Specifically, the 
authors estimated that borrowers who received NFMC counseling were 1.7 
times more likely to "cure" their foreclosure (i.e., be removed from 
the foreclosure process by their mortgage servicer) than borrowers who 
did not receive NFMC counseling. The authors also estimated that loan 
modifications received by NFMC clients in the first 2 years of the 
program resulted in monthly mortgage payments that averaged $267 less 
than they would have paid without the program's help. Additionally, 
the study found that in 2008, borrowers who received NFMC counseling 
before a loan modification had an estimated 53 percent better chance 
of bringing their mortgages current than borrowers who did not receive 
premodification counseling.[Footnote 5] Other studies of foreclosure 
prevention counseling have also found that the timing of the 
counseling was critical and that the earlier in the foreclosure 
process borrowers received counseling, the more likely they were to 
have a positive outcome.[Footnote 6] 

The findings on the impact of prepurchase counseling are less clear. 
For example, a 2001 study analyzed data on the performance of about 
40,000 mortgages made under a Freddie Mac program for low-to moderate- 
income homebuyers, a large majority of whom received prepurchase 
counseling.[Footnote 7] The authors compared the loan performance of 
program participants who received different types of prepurchase 
counseling to the loan performance of participants who did not. The 
study found that borrowers who underwent individual and classroom 
counseling were 34 and 26 percent less likely, respectively, to become 
90 days delinquent on their mortgages than similar borrowers who did 
not undergo counseling.[Footnote 8] However, subsequent studies have 
found either no effect on loan performance or effects that were 
potentially attributable to other factors. For example, a 2008 study 
of about 2,700 mortgage borrowers found that prepurchase counseling 
had no effect on a borrower's propensity to default.[Footnote 9] A 
2009 study examined a legislated pilot program in 10 Illinois ZIP 
codes that mandated prepurchase counseling for mortgage applicants 
whose credit scores were relatively low or who chose higher-risk 
mortgage products such as interest-only loans. Although the authors 
found that mortgage default rates for the counseled low-credit score 
borrowers were lower than those for a comparison group, the authors 
attributed this result primarily to lenders tightening their screening 
of borrowers in response to stricter regulatory oversight.[Footnote 10] 

Additional empirical research on the impact of housing counseling is 
under way at HUD and Fannie Mae. HUD's Office of Policy Development 
and Research issued a broad overview of the housing counseling 
industry in 2008 and is currently conducting two studies on mortgage 
outcomes related to foreclosure mitigation and prepurchase counseling 
programs.[Footnote 11] The foreclosure mitigation study will follow 
880 individuals and evaluate mortgage outcomes 12 months after 
counseling ends. HUD officials said that they expected the study to be 
published in 2012. The prepurchase counseling study will track 1,500 
to 2,000 individuals who receive different types of counseling (one-on-
one, group, Internet, or telephone) or no counseling. HUD officials 
said that they expected data collection for this study to begin in 
2012. In addition, Fannie Mae is conducting both prepurchase and post-
purchase counseling studies. According to Fannie Mae officials, the 
prepurchase study will track over a 2-year period the loan performance 
of borrowers who received counseling prior to purchasing a home. The 
post-purchase study will evaluate the impact of telephone counseling 
on existing homeowners who receive loan modifications through HAMP. 

Measuring the Effectiveness of Homeownership Counseling Presents 
Challenges: 

Conducting research on homeownership counseling outcomes is 
challenging for a variety of reasons, and limitations in the 
methodologies used in existing studies make it difficult to generalize 
the results or compare outcomes across various studies. According to 
housing counseling researchers we spoke with, the primary barrier in 
the study of housing counseling is a lack of data. Long-term data on 
counseling outcomes are limited because of the difficulty of tracking 
counseling recipients after the counseling ends. In addition, many 
counseling agencies are hesitant to request sensitive personal 
information from clients. One researcher we spoke with told us that 
the ability to track loan performance over time is critical to an 
effective assessment of housing counseling programs. For this reason, 
some counseling researchers have begun working with lenders and 
mortgage servicers to access information on the payment status (e.g., 
current or delinquent) of counseling recipients and the long-term 
outcomes of their mortgages. Another limitation of the current 
research is the lack of experimental research design, which is 
considered the best approach for evaluating differences in an 
intervention such as counseling and comparing it to no intervention. 
[Footnote 12] We did not identify any published studies that evaluated 
homeownership counseling using an experimental design. For this and 
other reasons, researchers have been hesitant to draw firm conclusions 
from the published literature. For example, differences among 
counseling programs--in terms of curriculum, intervention method 
(e.g., one-on-one, telephone, or classroom), level of intervention 
(e.g., intensity or amount of time spent counseling), and outcome 
measures--make it difficult to draw broader conclusions about the 
impact of housing counseling. 

Establishing meaningful measures of the impact of homeownership 
counseling programs is also a significant challenge. Our recent 
evaluation of Treasury's Financial Education and Counseling Pilot 
Program illustrates this point.[Footnote 13] As a condition of 
receiving grant funds under the program, grantees are required to 
report on the results of five performance goals within 6 months of 
disbursement and annually thereafter. We found that some grantees were 
calculating the results of their impact measures in erroneous or 
misleading ways or were not fully capturing meaningful information, 
potentially limiting the usefulness of these data for assessing 
program effectiveness. For example, one grantee inaccurately 
calculated the average percentage increase in prospective homebuyer 
savings. According to the grantee's calculation, a participant who 
began a financial education and counseling program with no savings but 
subsequently saved $500 was shown to have a 50,000 percent increase in 
savings. In fact, a percentage increase cannot be meaningfully 
calculated from zero savings because any percentage increase on zero 
is infinite. We also identified alternatives to the methods of 
calculating impact measures that the grantees were using. For example, 
we noted that instead of just measuring changes in clients' savings, 
it might be advantageous to focus on net savings--that is, savings 
minus debt--to provide a more complete picture of an individual's 
financial situation. 

Treasury officials told us that they had discussed the specific impact 
measures with each grantee in the pilot program but had not provided 
guidance on how to calculate the results. We recommended that Treasury 
provide additional guidance or technical assistance to the grantees on 
how to accurately and meaningfully calculate the results of the impact 
measures. Treasury stated that it concurred with the observations in 
our report and plans to provide grantees with supplemental guidance on 
impact measures before the next reporting deadline. 

Our Work Has Identified Shortcomings in the Implementation of Some 
Homeownership Counseling Requirements: 

In prior work, we found shortcomings in HUD's and Treasury's 
implementation of homeownership counseling requirements for the HECM 
and HAMP programs. In 2009, we evaluated HUD's implementation of the 
counseling requirements associated with the HECM program and found 
that HUD's internal controls did not provide reasonable assurance that 
counseling providers were complying with the program requirements. 
[Footnote 14] GAO's undercover participation in 15 HECM counseling 
sessions found that while the counselors generally conveyed accurate 
and useful information, none of the counselors covered all of the 
topics required by HUD, and some overstated the length of the sessions 
in HUD records. For example, 7 of the 15 counselors did not discuss 
required information about alternatives to HECMs, and 6 of the 15 
counselors overstated the length of the session. HUD had several 
internal controls designed to help ensure that counselors conveyed 
required information to prospective HECM borrowers but had not tested 
the effectiveness of these controls and lacked procedures to help 
ensure that records of counseling sessions were accurate. Because of 
these weaknesses, some prospective borrowers may not have received all 
of the information necessary to make informed decisions about 
obtaining a HECM. 

We recommended specific changes that HUD should make to improve the 
effectiveness of the agency's internal controls so that they provided 
reasonable assurance of compliance with HECM counseling requirements. 
Since our report, HUD has implemented our recommendations by creating 
additional internal controls and guidance for counselors on how to 
comply with program responsibilities, as well as developing a "mystery 
shopping" initiative to better evaluate compliance among HECM 
counselors. 

In 2009, we also evaluated Treasury's implementation of the 
foreclosure mitigation counseling requirements of HAMP.[Footnote 15] 
We found that Treasury did not plan to systematically track borrowers 
with high debt burdens, who were required to obtain foreclosure 
mitigation counseling, to determine whether they actually received 
counseling or if it was effective. Treasury officials told us that 
they made this decision because they did not want to deny a loan 
modification to borrowers who successfully made modified payments 
during a 90-day trial period but did not obtain counseling. Treasury 
also did not want to delay modifications under the program until 
servicers had arranged to coordinate with counselors to track whether 
borrowers obtained counseling. We noted that without knowing whether 
borrowers who were required to obtain counseling actually did so or 
evaluating the performance of counseled and noncounseled borrowers, 
Treasury would not know whether the requirement was meeting its 
purpose of reducing redefaults among borrowers with high debt burdens. 

We recommended in 2009 that Treasury consider methods of monitoring 
whether borrowers required to receive housing counseling as part of 
HAMP modifications did receive it and seek to determine whether the 
counseling did limit redefaults. Treasury staff said in 2010 that they 
had considered options for monitoring the proportion of borrowers that 
obtained counseling but had determined that implementing a monitoring 
process would be too burdensome for Treasury and mortgage servicers. 
Additionally, Treasury officials said they had no plans to assess the 
effectiveness of counseling in limiting redefaults, in part because 
they believed that the benefits of counseling on the performance of 
borrowers with high debt burdens were well documented. We continue to 
believe that monitoring the extent to which borrowers receive 
counseling and the redefault rates for counseled and noncounseled 
borrowers would provide valuable information about whether the 
counseling requirement is having its intended effect. 

HUD is Creating a New Office for Its Housing Counseling Activities, 
but Funding Is Uncertain: 

To enhance consumer protections for homebuyers and tenants, the Dodd- 
Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) 
requires HUD to establish an Office of Housing Counseling.[Footnote 
16] This office is mandated to perform a number of functions related 
to homeownership and rental housing counseling, including establishing 
housing counseling requirements, standards, and performance measures; 
certifying individual housing counselors; conducting housing 
counseling research; and performing public outreach. The office is 
also mandated to continue HUD's role in providing financial assistance 
to HUD-approved counseling agencies in order to encourage successful 
counseling programs and help ensure that counseling is available in 
underserved areas. 

Currently, HUD's housing counseling program operates out of the 
Program Support Division within the Office of Single-Family Housing. 
[Footnote 17] HUD supports housing counseling through the division in 
two ways. First, it approves and monitors housing counseling agencies 
that meet HUD criteria and makes information about these agencies 
available to consumers on HUD's website. According to HUD officials, 
as of August 2011, about 2,700 counseling agencies were HUD-approved. 
Second, HUD annually awards competitive grants to approved agencies to 
help them carry out their counseling efforts. HUD's housing counseling 
program provides funding for the full spectrum of housing counseling, 
including prepurchase counseling, foreclosure mitigation counseling, 
rental housing counseling, reverse mortgage counseling for seniors, 
and homeless assistance counseling. HUD-approved agencies report to 
HUD on the number and type of service interactions (e.g., counseling 
sessions) they have with clients. Self-reported data on homeownership 
counseling conducted by these agencies indicate that service 
interactions for foreclosure mitigation counseling rose from about 
171,000 in 2006 to more than 1.4 million in 2010, while service 
interactions for prepurchase counseling declined from about 372,000 to 
about 245,000 over the same period.[Footnote 18] 

Besides these two main functions, the Program Support Division and 
other HUD staff perform other counseling-related activities, some of 
which are similar to the functions the Dodd-Frank Act requires of the 
new counseling office. For example, HUD has developed standards and 
protocols for reverse mortgage counseling, certifies individual 
reverse mortgage counselors, is conducting research on the impact of 
homeownership counseling, and recently launched a public awareness 
campaign on loan modification scams. 

A working group within HUD is in the process of developing a plan for 
the new counseling office. According to HUD officials, the primary 
change needed to create the new office is the reassignment of staff 
who spend time on housing counseling activities but also have other 
responsibilities. In July 2011, we reported that HUD expected the new 
office to consist of approximately 160 full-time staff members, but 
HUD has indicated more recently that the office may be considerably 
smaller. In order to move forward with the establishment of the office 
and the appointment of a Director of Housing Counseling, HUD must 
submit a reorganization plan to Congress. According to a HUD official, 
HUD is still developing its proposal for the new counseling office and 
is unable to estimate when it will be submitted to Congress. 

HUD officials told us that the new counseling office would have 
advantages over their current organizational structure. They indicated 
that having dedicated resources, staff, and leadership would raise the 
profile of the housing counseling function and help the agency build a 
more robust capacity in this area. One official noted that getting 
sufficient information technology resources for housing counseling had 
been difficult and said that a separate counseling office might be 
able to compete more effectively with other parts of the agency for 
these resources. HUD officials also indicated that the new office 
would be organized to help the agency better anticipate and respond to 
changing counseling needs and improve interaction with counseling 
industry stakeholders. For example, the officials said that the new 
office would be organized around functional areas such as policy, 
training, and oversight, making it easier for industry stakeholders to 
direct their questions or concerns to the appropriate HUD staff. 
Additionally, HUD officials told us that the office would work with 
the Bureau of Consumer Financial Protection's Office of Financial 
Education to coordinate the housing counseling activities of both 
organizations. 

Mortgage industry participants, consumer groups, and housing 
researchers we spoke with were supportive of the new housing 
counseling office and believed that it offered opportunities to 
enhance HUD's role in the housing counseling arena. For example, some 
of the consumer groups stated that the office could help standardize 
counseling practices and publicize best practices, further elevating 
and professionalizing the counseling industry. In addition, 
representatives from several of the consumer groups and researchers 
with whom we met stated that the office could help enhance 
coordination among counseling agencies by providing opportunities for 
improved training, networking, and communication. Furthermore, they 
said that the office could potentially support improved data 
collection for research on the impact of housing counseling. 

Budget constraints could affect the establishment of the new 
counseling office and reduce the scale of HUD's housing counseling 
activities. Although the Dodd-Frank Act authorized $45 million per 
year through 2012 for the operations of the new office, HUD had not 
received any appropriations for this purpose as of August 2011. In 
addition, appropriations for fiscal year 2011 eliminated HUD's housing 
counseling assistance funds, which are primarily grant funds for 
approved counseling agencies.[Footnote 19] HUD officials said they 
planned to award and obligate about $10 million in unspent fiscal year 
2010 counseling assistance funds in the 2011 fiscal year. However, the 
officials said that some counseling agencies had already reduced the 
level of services they provided due to the elimination of the fiscal 
year 2011 funds. Housing counseling groups we spoke with said that the 
cuts in HUD funding, which they use to leverage private funds, 
ultimately could result in fewer counseling services for prospective 
and existing homeowners unless private funds make up the difference. 

Chairman Biggert, Ranking Member Gutierrez, and Members of the 
Subcommittee, this concludes my prepared statement. I would be happy 
to answer any questions you may have at this time. 

Contact and Staff Acknowledgments: 

For further information on this testimony, please contact me at (202) 
512-8678 or cackleya@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this statement. Key contributors to this testimony include 
Steve Westley, Assistant Director; Randall Fasnacht; Alise Nacson; and 
Emily Chalmers. 

[End of section] 

Related GAO Products: 

Financial Education and Counseling Program. [hyperlink, 
http://www.gao.gov/products/GAO-11-737R]. Washington, D.C.: July 27, 
2011. 

Mortgage Reform: Potential Impacts of Provisions in the Dodd-Frank Act 
on Homebuyers and the Mortgage Market. [hyperlink, 
http://www.gao.gov/products/GAO-11-656]. Washington, D.C.: July 19, 
2011. 

Troubled Asset Relief Program: Treasury Actions Needed to Make the 
Home Affordable Modification Program More Transparent and Accountable. 
[hyperlink, http://www.gao.gov/products/GAO-09-837]. Washington, D.C.: 
July 23, 2009. 

Reverse Mortgages: Product Complexity and Consumer Protection Issues 
Underscore Need for Improved Controls over Counseling for Borrowers. 
[hyperlink, http://www.gao.gov/products/GAO-09-606]. Washington, D.C.: 
June 29, 2009. 

[End of section] 

Footnotes: 

[1] Reverse mortgages are a type of loan against home equity available 
to seniors. Through its HECM program, HUD insures reverse mortgages, 
which are made by private lenders, and oversees the agencies that 
provide mandatory counseling to prospective HECM borrowers. 

[2] A major purpose of HAMP is to modify the first-lien mortgages of 
homeowners in danger of foreclosure. Under the first-lien program, 
borrowers with high levels of household debt must agree to obtain 
counseling. 

[3] A list of related GAO products on which this statement is based 
can be found at the end of this testimony. 

[4] Treasury's Financial Education and Counseling Pilot Program, 
authorized pursuant to Section 1132 of the Housing and Economic 
Recovery Act of 2008 (Pub. L. No. 110-289), awards grants to eligible 
organizations, including HUD-approved housing counseling agencies, to 
provide financial education and counseling services to prospective 
homebuyers. 

[5] Neil S. Mayer, Peter A. Tatian, Kenneth Temkin, and Charles A. 
Calhoun, National Foreclosure Mitigation Counseling Program 
Evaluation: Preliminary Analysis of Program Efforts, September 2010 
Update, prepared for NeighborWorks® America (Washington, D.C., Urban 
Institute, 2010). The study focused on the approximately 800,000 
borrowers who received NFMC counseling from January 2008 through 
December 2009 and a comparison sample of non-NFMC-counseled homeowners. 

[6] Lei Ding, Roberto G. Quercia, and Janneke Ratcliffe, "Post-
purchase Counseling and Default Resolution among Low-and Moderate-
Income Borrowers," Journal of Real Estate Research, vol. 30, no. 3 
(2008). 

[7] Abdighani Hirad and Peter M. Zorn, A Little Knowledge is a Good 
Thing: Empirical Evidence of the Effectiveness of Pre-Purchase 
Homeownership Counseling, Joint Center for Housing Studies of Harvard 
University, Low Income Homeownership Working Paper Series 01.4 
(Cambridge, Mass., August 2001). 

[8] Hirad and Zorn, A Little Knowledge Is a Good Thing: Empirical 
Evidence of the Effectiveness of Pre-Purchase Homeownership Counseling. 

[9] Roberto Quercia and Jonathan S. Spader, "Does Homeownership 
Counseling Affect the Prepayment and Default Behavior of Affordable 
Mortgage Borrowers?" Journal of Policy Analysis and Management, vol. 
27, no. 2 (2008). 

[10] Sumit Agarwal, Gene Amromin, Itzhak Ben-David, Souphala 
Chomsisengphet, and Douglas D. Evanoff, Do Financial Counseling 
Mandates Improve Mortgage Choice and Performance? Evidence from a 
Legislative Experiment, working paper 2009-07 (Federal Reserve Board 
of Chicago, 2009). 

[11] Christopher E. Herbert, Jennifer Turnham, and Christopher N. 
Rodger, The State of the Housing Counseling Industry, Abt Associates 
for the Department of Housing and Urban Development (Washington, D.C., 
September 2008). 

[12] Experimental design involves random assignment of subjects to 
treatment and control groups to isolate the impact of the treatment. 
In the context of prepurchase homeownership counseling, one group of 
prospective homebuyers would receive counseling (treatment group) and 
the other would not (control group). Experimental design can mitigate 
the problem of "selection bias." Individuals who receive housing 
counseling, either on their own or by enrolling in a research study, 
represent a "self-selected" population. Therefore, they may be 
systematically different than individuals who do not seek counseling, 
and this potential bias makes generalizing research results for the 
self-selected population problematic. 

[13] GAO, Financial Education and Counseling Program, [hyperlink, 
http://www.gao.gov/products/GAO-11-737R (Washington, D.C.: July 27, 
2011). 

[14] GAO, Reverse Mortgages: Product Complexity and Consumer 
Protection Issues Underscore Need for Improved Controls over 
Counseling for Borrowers, [hyperlink, 
http://www.gao.gov/products/GAO-09-606] (Washington, D.C.: June 29, 
2009). 

[15] GAO, Troubled Asset Relief Program: Treasury Actions Needed to 
Make the Home Affordable Modification Program More Transparent and 
Accountable, [hyperlink, http://www.gao.gov/products/GAO-09-837] 
(Washington, D.C.: July 23, 2009). 

[16] Dodd-Frank Act, sec. 1442 (codified at 42 U.S.C. sec. 3533(g)). 

[17] The Program Support Division has staff in HUD headquarters in 
Washington, D.C., and in HUD's four homeownership centers located in 
Atlanta, Georgia; Denver, Colorado; Philadelphia, Pennsylvania; and 
Santa Ana, California. 

[18] Counseling agencies may have multiple service interactions with 
the same client. Some of the HUD-approved counseling agencies that 
report service interaction data do not receive HUD funds, and those 
that do receive HUD grants also rely on other funding sources, 
according to HUD officials. As a result, the service interaction data 
do not represent solely the counseling services provided with HUD 
funds. 

[19] In fiscal year 2010, HUD was appropriated $88 million for housing 
counseling assistance. The President's budget for fiscal year 2012 
requests $88 million for HUD housing counseling assistance. 

[End of section] 

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