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1. 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.4 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 />satisfy this requirement unless there is affirmative confirmation and documented proof that <br />the client has reviewed the olic in the file. Clients that choose too t-out and not share their <br />information with affiliated third -parties cannot be uploaded into the DCS for payment. <br />4. Documentation of DTI. Using the verified budget, the Contractor will calculate the back end <br />DTI ratio. The back end DTI ratio is the ratio of the borrower's total monthly debt payments <br />to the borrower's Monthly Gross Income. A standard for calculating back end DTI is included <br />in the Counseling Protocol on the NFMC members' website. A document indicating the <br />calculation must be in the file, as well as evidence of income and debt. A credit report is not <br />sufficient to calculate the DTI ratio, as income must also be validated. <br />5. Update on Verified Budget. Contractor will document borrower's ability to keep to crisis <br />and/or long-term budget whichever was discussed during Level 4a counseling. This can <br />include but is not limited to; new documentation to verify budget, mortgage statement or credit <br />report showing timely payments to the trial modification or a copy of the client's permanent <br />modifications dated after the initial Level 4a counseling session. <br />It 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 />{00028595-1) <br />Page 31 of 39 <br />