Contract - IHCDA - Mortgage Foreclosure Prevention Counseling

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4. Privacy Policy.' Contractor must provide to all clients a copy of its privacy policy. Proof that the client received the policy must be maintained in the file. Such proof can include a statement signed by the homeowner or an electronic signature, if applicable. Although it is a best practice to provide the client with the privacy policy at the time of counseling, the Contractor may elect to share the privacy policy after the counseling occurs. If that is the case, Contractor must keep on file proof that the policy was sent to the homeowner via e-mail, fax, or postal mail. Having access to the privacy policy on Contractor's website does not satisfy this requirement unless there is affirmative confirmation and documented proof that the client has reviewed the policy.in the file. Clients that choose too t-out and not share their information with affiliated third -parties cannot be uploaded into the DCS for payment. 5. Budaet. Contractor must develop a budget for each client based on client's oral representation of their expenses, debts, and available sources of income. One example of a worksheet Contractor may use to develop this budget can be found on the NFMC members' website at www.nfmcmembers.org. 6. Action Plan. Contractor must develop a written Action Plan for follow-up activities to be taken by the client and review this Action Plan with the client. The Action Plan must be clearly labeled in the client file. When developing this Action Plan, it is expected that the Contractor will do a comprehensive analysis of the homeowner's situation and recommend a best plan of action. The Action Plan must include the counselor's assessment of the client's situation with a client -specific recommendation for a counseling plan of action. A general handout with a variety of workout options or "Actions" is not acceptable. If the assessment and recommendation are part of the counselor notes, IHCDA requires that the information is transferred to a form titled Action Plan so that the assessment and course of action are clearly defined for the client and for compliance testing. The National Industry Standards provide guidance on what should be included in an Action Plan. (See www.nw.org/nfmc) NFMC has also created a template Action Plan which is available on the NFMC members' website; use of this template is not required. However, Contractor must have a conforming Action Plan in each client file. 7. Making Home f fordrrble Pro ram Eligibility. Contractor must determine and document if client is eligible for assistance through the Making Home Affordable Program. Documentation that a screening occurred for each type of available assistance listed below. Available products in the MHA are subject to changes mandated by the U.S. Department of Treasury, the administrators of MHA. Types of assistance offered through the Making Home Affordable Program are; a. Refinance. Contractor must determine and document eligibility by requesting information and analyzing if. (a) client is the owner occupant of a one- to four -unit property (required by the NFMC Program, not HARP); (b) loan is a first lien, conventional mortgage that is owned or guaranteed by Fannie Mae or Freddie Mac --- counselor will verify this by checking the GSE's web look -up tools; (c) the client is current on mortgage (client hasn't missed more than one payment in the last 12 months and has not missed any payments in the past 30 days); (d) the client must have a source It is acceptable for Contractor to combine the Authorization Form, Disclosure Statement, and Privacy Policy into a single document which the client signs and the Contractor maintains in the client file. (00028595-1) Page 24 of 39