HUD’s HECM roster certification is governed by 24 CFR 206.304 which requires housing counselors not be listed on HUD’s Credit Alert Interactive Response System (CAIVRS). The proposed rule “Housing Counseling Program: New Certification Requirements” for housing counselor certification published September 13, 2013, proposed to require only that a HUD-certified housing counselor pass the requisite examination, be employed by a participating agency, and be certified by HUD as competent to provide housing counseling services.