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The U.S. Department of Housing and Urban Development (HUD) published a request for information (RFI) on October 2, 2025 titled “Future of the HECM and HMBS Programs and Opportunities for Innovation in Accessing Home Equity.” The title alone underscores the RFI’s importance for all participants in HUD’s Home Equity Conversion Mortgage (HECM) program, including lenders, servicers and investors.

The RFI acknowledges a recent downturn in borrower participation in the HECM program, noting that “HECM endorsements declined by 59 percent since 2022.” It further highlights that Ginnie Mae’s HECM mortgage-backed securities (HMBS) program has seen a decrease in the total dollar amount of HECMs securitized since 2022, “with only $6.3 billion in [unpaid principal balance] being securitized in 2024, nearly the same level as that of a decade ago.” The RFI’s release indicates that HUD recognizes the HECM and HMBS programs may need updates to better facilitate their goal of providing “access to home equity for senior homeowners.”

Following the initial framing of the issue, the RFI solicits general feedback from interested parties regarding “the appropriate role of the HECM and HMBS programs and enhancements to these programs.” The RFI also provides a list of 21 questions related to the current and future state of the HECM and HMBS programs that “HUD is particularly interested in receiving input from interested parties.” The questions are grouped into the following topics:

  • Program Performance, Market Role, and Emerging Risks
  • Consumer Interest and Demand
  • Origination Volumes
  • Liquidity
  • Program Improvements

The questions range from very broad – “Are there any statutory changes that would improve the HECM or HMBS programs?” – to more specific to certain aspects of each program – “Does the Life Expectancy Set Aside (LESA) adequately cover borrowers’ actual property charges throughout the life of the HECM?” Overall, the RFI provides any party associated with the HECM or HMBS programs the opportunity to comment on how to reshape those programs going forward. Comments are due by December 1, 2025, and may be submitted electronically through the Federal eRulemaking Portal or by mail to the Regulations Division, Office of General Counsel, Department of Housing and Urban Development at 451 7th Street SW, Room 10276, Washington, D.C. 20410-0500.

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Photo of James W. Wright Jr. James W. Wright Jr.

Jay Wright is a partner in the firm’s Banking and Financial Services and Litigation practice groups. Jay has earned his Accredited Mortgage Professional (AMP) designation through the Mortgage Bankers Association (MBA), and is one of a small number of lawyers who have achieved…

Jay Wright is a partner in the firm’s Banking and Financial Services and Litigation practice groups. Jay has earned his Accredited Mortgage Professional (AMP) designation through the Mortgage Bankers Association (MBA), and is one of a small number of lawyers who have achieved this status.

Jay’s practice focuses on financial services litigation and regulation, and he is actively involved in lawsuits and disputes across the country representing companies involved in a wide array of state and federal law claims. His representation includes general defense of various claims against financial institutions, mortgage companies, and other commercial entities. Many of these claims involve allegations of wrongful foreclosure proceedings or violations of the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), and Federal Housing Administration (FHA) regulations, as well as various deceptive trade practices claims under state law.

Photo of John Thomas Mostellar III John Thomas Mostellar III

Tom Mostellar is an associate in the firm’s Banking and Financial Services Practice Group.

Tom received his J.D. (magna cum laude) from Tulane University School of Law, where he was an articles editor for the Tulane Law Review. He has…

Tom Mostellar is an associate in the firm’s Banking and Financial Services Practice Group.

Tom received his J.D. (magna cum laude) from Tulane University School of Law, where he was an articles editor for the Tulane Law Review. He has a B.S. in Business Administration from Washington & Lee University.