(Editor’s note: HUD announced that the RFI comment period was extended to January 5, 2026.)
With input from NRMLA’s committees and executive leadership, NRMLA submitted a detailed comment letter to the leadership at FHA and Ginnie Mae that lays out a prioritized menu of fixes to restore borrower access, investor demand and program solvency.
The letter was submitted in response to a Request for Information published in the October 2, 2025 Federal Register. Comments were due December 1, 2025.
Why it matters: NRMLA notes that reverse mortgages remain a critical retirement tool for over 1.3 million seniors — but some program policies are shrinking access and increasing risk to the FHA insurance fund.
Key issues flagged:
- Upfront MIP too high, especially for low-draw borrowers.
- CMT-to-SOFR mismatch is hurting HMBS pricing and investor demand.
- 98 percent MCA buyouts strain issuer liquidity and shift expensive servicing to FHA.
- Operational drag from duplicative appraisals, restrictive LESA caps, and over-documentation.
Top recommendations:
- Convert upfront MIP to a risk-based pricing structure.
- Move all HECMs to SOFR to eliminate basis risk.
- Create a New HMBS product to securitize loans after 98 percent MCA instead of forcing assignment.
- Allow private servicers to administer post-assignment loans under HUD oversight.
- Streamline underwriting and appraisal policies.
The takeaway: NRMLA says targeted technical fixes could expand access for seniors, cut federal costs, and restore HMBS investor confidence.
A copy of NRMLA’s comment letter can be downloaded by logging into the Comment Letters section of NRMLAonline.org.
