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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 />IIICDA and NFMC to open files to be reviewed for program monitoring and compliance <br />purposes, and (c) allow IHCDA and NFMC to conduct follow-up with client related to <br />program evaluation. Clients may opt -out of (c) above only, but proof of this opt -out must be <br />retained in the client's file. Clients that opt out of (a) or (b) above cannot be uploaded into <br />the DCS. Files uploaded in to the DCS without a signed authorization can create a legal <br />liability, therefore the Contractor must ensure client files submitted to the DCS have a signed <br />authorization form in the client file. Contractor is responsible for performing counseling <br />within the limits of the laws in the 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.2 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.olic 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 policy in the file. Clients that choose toopt-out and not share their <br />information with affiliated third -parties cannot be uploaded into the DCS for payment. <br />4. Budget Verification. Contractor must engage in budget verification during which s/he <br />reviews documented evidence provided by the client to establish true debt obligations (e.g., <br />credit report), monthly expenses (e.g., monthly bills, bank statements, mortgage statement, <br />credit card statement, utility bill) and spending patterns, and realistic opportunities for income <br />(e.g., tax returns, pay stubs, profit and loss statement, third party verification). Note: a credit <br />report alone does not satisfy the budget verification requirement. Contractor should collect <br />verification of all income, expenses, and debt as stated by the client (must be within previous <br />30 days). A credit report alone does not satisfy the budget verification requirement. <br />S. Verification of Action Taken. Contractor should take a ro riate actions upon the steps <br />outlined in the written Action Plan (created during Level One). Contractor must have <br />documented evidence of "action" taken on behalf of the client. This requires more than the <br />I It is acceptable for Contractor to combinc.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 26 of 39 <br />