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K . Confidentiality of Client Data <br /> Developer will observe all Privacy Act requirements and keep client data in locked file <br /> cabinets or password - protected electronic files . <br /> XII . Homebuyer Counseling and Education <br /> A . Referral to Counseling and Education Program <br /> Upon notification of approval of an application for assistance, buyers will be referred to <br /> a third party Grantee- approved and HUD - approved program that offers at least eight <br /> hours of pre- purchase counseling and education . If buyers have already completed such <br /> a program , Developer must determine if the program meets Grantee and NSP3 <br /> requirements and must verify completion by obtaining and filing a certificate of <br /> completion . If the pre - purchase counseling and education does not meet requirements, <br /> buyers will have to complete training delivered by a HUD - approved counselor . <br /> Be Certificate of Completion <br /> Upon successful completion of a counseling and education program , Buyers will receive <br /> a certificate of completion . No buyers will be allowed to sign a sale agreement for an <br /> NSP3 home unless the completion of counseling and education has been verified by <br /> Developer and a copy filed in Developer' s records . <br /> XIII . Waiting - List <br /> A . Requirements for Waiting Lists <br /> Developer must establish and maintain a waiting list of all prospective homebuyers who <br /> are approved for assistance . Grantee may waive this requirement at its sole discretion if <br /> Developer demonstrates conclusively that a waiting list serves no purpose, because the <br /> number of homes available for sale exceeds the number of qualified buyers . <br /> Be Waiting List Procedures <br /> Developers will follow these procedures . <br /> 1 . Priority for selecting a completed home will be determined by the date <br /> that a client' s application for assistance was approved (that is, the client with the earlier <br /> date of approval shall have priority for selection . ) <br /> 2 . As a home or group of homes becomes available for sale, the home ( s ) will <br /> be offered first to the client with the highest priority, and if not selected , then to the <br /> client with the second highest priority, etc . <br /> 19 <br />