Jump to Content
ABA: The American Bankers Association
Skip Section Navigation

How should the bank provide a list of homeownership counseling organizations when the applicant currently resides outside the United States?

A loan applicant currently residing in France is purchasing a primary residence in the United States. The Real Estate Settlement Procedures Act (RESPA) and Regulation X require the bank to provide a list of homeownership counseling organizations that provide relevant counseling services in the loan applicant's location to this loan applicant. How should the bank provide a list of homeownership counseling organizations when the applicant currently resides outside the United States?

The Consumer Financial Protection Bureau issued the following interpretive guidance for this situation.

In circumstances where the applicant’s current address does not include a five-digit zip code, e.g., the applicant currently lives overseas, making it impossible to generate a list based on the zip code of the applicant’s current address, the lender may use the five-digit zip code of the property securing the mortgage to generate the list. (July 2019)

Compliance Hotline

Have a compliance-related question? We're here to help. Members, reach us by phone or email.