public-service · HUD housing counseling approval criteria
HUD's Structure and Staffing Requirements for Housing Counseling Agencies
Under 24 CFR 214.103, HUD requires counseling agencies to be nonprofits or government units with certified, experienced staff.
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What matters now
- An agency must be a private or public nonprofit, or a unit of local, county, or state government.
- Every staff member who provides housing counseling, homeownership or rental, must be individually HUD certified.
- At least half of an agency's counselors must also have at least 6 months of job experience in their role.
- These two requirements are part of 24 CFR 214.103's broader approval criteria, not the section's full list.
Under 24 CFR 214.103, a HUD-approved housing counseling agency must meet two conditions covered in this article: it must be organized as a private or public nonprofit or a unit of local, county, or state government, and its staff must meet HUD’s certification and experience standards — every counselor individually certified, with at least half also meeting a minimum experience threshold (24 CFR 214.103). The regulation does not create a list of approved agencies; it defines requirements an agency’s structure and staff must meet.
This original record-reading guide is a general reading aid, not cited evidence. It does not depict a source record; the article text and source links provide the facts.
Key points
(Source for the requirements below: 24 CFR 214.103.)
- An agency must be a private or public nonprofit, or a unit of local, county, or state government.
- Every staff member who provides housing counseling — homeownership or rental — must be individually HUD certified.
- At least half of the agency’s counselors must have at least 6 months of job experience in the counseling role they perform.
- These two requirements are part of 24 CFR 214.103’s broader approval criteria; the section does not identify which agencies or counselors currently hold approval.
The organizational structure requirement
The regulation sets a threshold on what kind of entity can qualify at all. As the rule states, “A housing counseling agency must function as a private or public nonprofit organization, or be a unit of local, county, or state government” (24 CFR 214.103).
A for-profit entity does not meet this threshold under the rule as written.
The staff certification and experience requirement
Beyond organizational form, the regulation sets a personnel standard that applies to every individual who counsels clients. The rule states: “All staff providing housing counseling, including homeownership counseling or rental housing counseling, must be HUD certified housing counselors, and at least half the agency’s counselors must have at least 6 months of experience in the job they will perform in the agency’s housing counseling program” (24 CFR 214.103).
This means two separate conditions have to hold at once: universal individual certification (no uncertified staff member may provide counseling, regardless of counselor mix), and an experience floor that applies to at least half of the counselor roster.
What this article does not answer
This article explains two of HUD’s approval criteria for housing counseling agencies — it is not a directory and does not summarize every requirement in 24 CFR 214.103. It does not tell readers where to find or how to search a current list of HUD-approved housing counseling agencies; readers looking for that list should go directly to HUD’s own current resources rather than relying on any secondhand list, since agency approval status can change.
This article also does not identify which specific agencies or individual counselors currently hold HUD approval or certification — the regulation quoted above states requirements those agencies and counselors must meet, not a roster of who currently meets them.
Regulatory history
The current text of 24 CFR 214.103 reflects a series of federal rulemakings: “[72 FR 55648, Sept. 28, 2007, as amended at 80 FR 75936, Dec. 7, 2015; 81 FR 90658, Dec. 14, 2016; 85 FR 47303, Aug. 5, 2020; 89 FR 75501, Sept. 16, 2024]” (24 CFR 214.103).