Laserfiche WebLink
In order to report a client as having received Level 4a counseling, the following documents must be <br />in the client's file: verification of client loan source, trial or permanent loan modification verification, <br />authorization, disclosure, privacy policy, budget verification, documentation of back end DTI, Action <br />Plan that would include applicable referrals, and date of follow-up meeting. <br />The Contractor must certify that all NFMC clients are owner -occupants of their homes at the <br />time they receive counseling. By existing statute, NFMC clients must be owner -occupants of <br />single-family (one- to four -unit) properties with mortgages in default or in danger of default. <br />The Contractor is responsible for ensuring proper documentation exists in client files. The <br />Contractor cannot receive payment for a client until after all the required actions for the level have <br />occurred and have been documented accordingly. <br />Level 4b Counseling: (Counseling) Level 4b ($150.00) can only be reported when a Level 4a client <br />has completed one follow-up session and the following documents are in the file: <br />Authorization. If not already on file, Contractor must collect a signed authorization form <br />from the client or have other legally -permissible client authorization on record that will allow <br />the Contractor to (a) submit client -level information to the DCS for this grant, (b) allow <br />IHCDA and NFMC to open files to be reviewed for program monitoring and compliance, and <br />(c) allow IHCDA and NFMC to conduct follow-up with client related to program evaluation. <br />Clients may opt -out of (c) above only, but proof of this must be retained in the client's file. <br />Clients that opt out of (a) or (b) above cannot be uploaded into the DCS. Files uploaded in to <br />the DCS without a signed authorization can create a legal liability, therefore the Contractor <br />must ensure client files submitted to the DCS have a signed authorization form in the client <br />file. Contractor is responsible for performing counseling within the limits of the laws in the <br />State of Indiana. <br />2. Disclosure. Contractor must provide to all clients a disclosure statement. The disclosure <br />statement must explicitly describe the various types of services the Contractor provides and <br />any financial relationships between the Contractor and any other industry partners. The <br />disclosure must state clearly that the client is not obligated to receive any other services <br />offered by the Contractor or its exclusive partners. This must be presented to the client at the <br />time of counseling. Proof that the client received the disclosure must be maintained in the <br />file. Such proof can include a statement signed by the homeowner or an electronic signature, <br />if applicable. <br />3. Privacy Policy.° Contractor must provide to all clients a copy of its privacy policy. Proof that <br />the client received the policy must be maintained in the file. Such proof can include a <br />statement signed by the homeowner or an electronic signature, if applicable. Although it is a <br />best practice to provide the client with the privacy policy at the time of counseling, the <br />Contractor may elect to share the privacy policy after the counseling occurs. If that is the <br />case, Contractor must keep on file proof that the policy was sent to the homeowner via e-mail, <br />fax, or postal mail. Having access to the privacy policy on Contractor's website does not <br />satisfythis his requirement unless there is affirmative confirmation and documented proof that <br />4It is acceptable for Contractor to combine the Authorization Form, Disclosure Statement, and Privacy Policy into a single <br />document which the client signs and the Contractor maintains in the client file. <br />(00024811-1) <br />Page 31 of 39 <br />