{ "source": "Cooked Index — occupational AI risk register", "page": "https://cookedindex.com/jobs/credit-counselors/", "methodology": "https://cookedindex.com/methodology", "notice": "Verdicts are re-examined as evidence accumulates. Re-fetch before relying on this; the page above always carries the current score.", "scored_at": "2026-08-11", "model": "claude-opus-5", "occupation": { "title": "Credit Counselors", "soc_code": "13-2071", "category": "Business", "us_employment": 27770, "median_annual_wage": 52230 }, "verdict": "EXPOSED", "risk_resistance": 39, "contested": false, "near_boundary": false, "dimensions": { "task_resistance": 8, "embodiment": 3, "liability_shield": 6, "trust_premium": 13, "judgment_accountability": 9 }, "reasoning": { "task_resistance": "An 8 reflects that the DMP mechanics — pulling tri-merge reports, amortizing balances at creditor-concession rates, generating the proposal packet, and sending 341-meeting and pre-discharge certificates — are already software output, while the parts that resist are the live sessions where a client understates their gambling or a spouse's income and you have to notice the gap between the stated budget and the actual bank statements; that's a minority of billable hours, not the majority, which is why it sits below the mixed midpoint.", "embodiment": "A 3 is right because the job runs on a phone headset, a screen-shared budget worksheet, and the HUD client management system; the only physical element is the occasional in-person foreclosure session or a homebuyer education class in a community room, and neither requires anything from your hands but a signature.", "liability_shield": "A 6 recognizes that HUD housing counselor certification and NFCC/FCAA credentials are real gatekeepers — 24 CFR 214 requires a certified counselor to deliver the session for the agency to bill HUD grant funds — but the certification protects the agency's funding stream, not you personally: no state licence, no malpractice exposure, and no client can sue you for a bad payoff projection the way they can sue a CPA.", "trust_premium": "A 13 is earned by the disclosure problem: a client who won't admit the payday loans or the co-signed car note gets a plan that fails in month four, and the 48-month DMP completion rate turns on whether they call you instead of dropping the draft — that's relationship as work product, though it's capped below the top band because most clients arrive through a creditor referral or a court-ordered bankruptcy course and never choose you by name.", "judgment_accountability": "A 9 fits because the discretion is real but bounded — you decide whether to route someone to a DMP, a Chapter 7 referral, or a loss-mitigation application, and you judge whether a proposed budget leaves enough for food — but creditor concession terms, HUD counseling protocols, and the agency's DMP eligibility thresholds set the frame, and the consequential calls (discharge, loan modification approval) are made by trustees, attorneys, and servicers, not you." }, "rationale": "The analytic core — pulling and interpreting credit reports, building household budgets, running debt-payoff scenarios, drafting debt management plan paperwork — is exactly the structured text-and-numbers work current AI does cheaply, and fintech apps already ship it free. What persists is the counseling itself: sitting with someone in financial shame, getting honest disclosure of spending, and holding them to a 48-month plan, plus HUD-certified housing counseling where a certified human must deliver the session for the agency to be funded. The modal worker at a nonprofit agency will see intake and analysis compressed while retained hours shift toward crisis, foreclosure, and bankruptcy-adjacent cases.", "outlook": "Headcount likely flat-to-down as free AI budgeting tools absorb intake and analysis, with surviving roles concentrated in HUD-certified housing counseling and crisis debt work at nonprofit and legal-aid agencies.", "what_would_raise_it": { "levers": [ { "dimension": "liability_shield", "change": "HUD's housing counseling certification rule (24 CFR 214, effective 2020) already requires a HUD-certified individual to deliver counseling for agency funding eligibility; extending an equivalent human-delivery requirement to the pre-bankruptcy credit counseling and debtor education certificates required under 11 U.S.C. 109(h)/111 — i.e., an EOUST rule stating an approved agency's certificate is invalid unless a certified counselor personally conducted the session rather than an automated module — would make a named human the signature point for a court-filed document", "plausibility": "plausible", "would_add": 5 }, { "dimension": "liability_shield", "change": "State DMP licensing regimes (e.g. NY Banking Law Art. 12-C, Maryland, Florida debt management service statutes) adding an explicit provision that a licensed counselor must review and sign each debt management plan agreement and that automated plan generation without counselor sign-off is an unlicensed practice, with personal exposure under state UDAP", "plausibility": "plausible", "would_add": 4 }, { "dimension": "task_resistance", "change": "Genuine two-tier structure: if intake, report pulls, budget build and payoff scenarios are absorbed by agency-side AI (already visible in NFCC member tooling), the retained caseload becomes foreclosure mitigation, imminent-bankruptcy triage, elder financial-abuse and coerced-debt cases — adversarial, document-scarce, disclosure-dependent work where the counselor negotiates with servicers and creditors by phone", "plausibility": "already happening", "would_add": 4 }, { "dimension": "judgment_accountability", "change": "Counselor-of-record duties in loss mitigation: if CFPB Reg X or servicer settlement terms recognize a certified counselor's written recommendation as a step servicers must respond to, the counselor owns a call (recommend modification vs. short sale vs. surrender) with a traceable consequence and a complaint path", "plausibility": "plausible", "would_add": 4 }, { "dimension": "trust_premium", "change": "Funder-side rather than consumer-side premium: HUD NOFA, state AG settlement funds, and bank CRA-driven grants specifying reimbursement per human counseling session (not per digital engagement) keeps someone paying for a person even when the client would accept an app", "plausibility": "already happening", "would_add": 3 } ], "ceiling_note": "Consumer willingness to pay directly for a human here is weak — the service is largely free at point of use and creditor/grant funded, so trust premium is capped by funder preference rather than client preference. Embodiment has no route." }, "adjudication": null, "employment_history": { "points": [ { "y": 2017, "emp": 35900, "wage": 44710 }, { "y": 2018, "emp": 35740, "wage": 45180 }, { "y": 2019, "emp": 32110, "wage": 45950 }, { "y": 2020, "emp": 30770, "wage": 46170 }, { "y": 2021, "emp": 31230, "wage": 47580 }, { "y": 2022, "emp": 29090, "wage": 47320 }, { "y": 2023, "emp": 27950, "wage": 48570 }, { "y": 2024, "emp": 28110, "wage": 50480 }, { "y": 2025, "emp": 27770, "wage": 52230 } ], "from": 2017, "to": 2025, "change_pct": -22.6, "comparable_from": 2019, "spans_soc_revision": true }, "pivots": [ { "slug": "personal-financial-advisors", "title": "Personal Financial Advisors", "verdict": "EXPOSED", "risk_resistance": 52, "median_wage": 105070, "overlap": 84, "skills_to_close": [ "Management of Financial Resources", "Management of Material Resources", "Operations Analysis", "Operations Monitoring" ] }, { "slug": "securities-commodities-and-financial-services-sales-agents", "title": "Securities, Commodities, and Financial Services Sales Agents", "verdict": "EXPOSED", "risk_resistance": 51, "median_wage": 78660, "overlap": 75, "skills_to_close": [ "Management of Financial Resources", "Management of Material Resources", "Management of Personnel Resources", "Monitoring" ] }, { "slug": "educational-guidance-and-career-counselors-and-advisors", "title": "Educational, Guidance, and Career Counselors and Advisors", "verdict": "EXPOSED", "risk_resistance": 58, "median_wage": 64330, "overlap": 72, "skills_to_close": [ "Social Perceptiveness", "Management of Personnel Resources", "Monitoring", "Instructing" ] } ], "license": "https://cookedindex.com/terms" }