Short answer: before an FHA-insured reverse mortgage, called a Home Equity Conversion Mortgage (HECM), each borrower, any non-borrowing spouse and any non-borrowing owner on the title must complete counseling with an independent HECM counselor. The counselor gives a signed Certificate of HECM Counseling, which HUD says stays valid for 180 days. The lender may not charge you fees or process the application until it has that certificate. This page covers federal rules only. It is general information, not legal or financial advice.
What a HECM is
HUD says the HECM is the only reverse mortgage insured by the U.S. federal government, that it lets you withdraw part of your home’s equity, and that borrowers may stay in their homes as long as property taxes and homeowner’s insurance are kept current (HUD, no date shown on the page, read October 30, 2026). The CFPB says a HECM is only for homeowners who are 62 and older, that borrowers make no monthly mortgage payments, and that interest and fees are added to the balance each month, so the balance grows (CFPB, last reviewed August 28, 2026). The age rule is in 24 CFR 206.33 (eCFR). See reverse mortgage vs personal loan.
What the law requires
The National Housing Act says a HECM is eligible for FHA insurance only if the borrower has received adequate counseling from an independent third party that is not directly or indirectly associated with or paid by anyone involved in originating or servicing the mortgage, funding the loan, or selling annuities, investments, long-term care insurance or other financial or insurance products (12 U.S.C. 1715z-20(d)(2)(B), LII, read October 30, 2026). Under subsection (f), the counselor must discuss:
- options other than a HECM, including other housing, social service, health and financial options;
- other home equity conversion options, such as sale-leaseback financing, deferred payment loans and property tax deferral;
- the financial implications of a HECM;
- that a HECM may have tax consequences, affect eligibility for federal and other public assistance programs, and have an impact on your estate and heirs; and
- any other information HUD requires.
The same section bars anyone from requiring you to buy insurance, an annuity or another product as a condition of the HECM, apart from title insurance, hazard, flood or other peril insurance, and other products HUD determines are customary and normal (12 U.S.C. 1715z-20(o)).
Who must attend
HUD’s regulation says the borrower, any Eligible or Ineligible Non-Borrowing Spouse, and any non-borrowing owner must receive counseling, and that the lender must give you a list of HECM counselors at the first contact (24 CFR 206.41(a), eCFR, text up to date as of October 28, 2026). HUD Handbook 4000.1 adds that a non-borrowing owner is someone on the title who is not a borrower or a borrower’s spouse, that an agent holding a durable power of attorney who signs for a legally competent borrower or Eligible Non-Borrowing Spouse must also complete counseling, and that for anyone lacking legal competency, counseling is completed by the person holding a power of attorney or a court-appointed conservator or guardian (II.B.1.c, sections dated 04/29/2024, HUD, Handbook update issued August 12, 2026, read October 30, 2026). For questions about a power of attorney, guardianship or a trust, talk to a lawyer.
Finding a counselor
The Handbook says the lender’s list must include the HUD intermediaries that counsel nationwide, agencies that counsel by telephone, and at least five agencies near you, including one within a reasonable driving distance for face-to-face counseling, and that it is your responsibility to contact an agency and schedule counseling without the lender’s help (II.B.1.a). HUD’s HECM page points to the HECM Counselor Roster and a phone line, (800) 569-4287 (HUD). You can also use the CFPB housing counselor search to find agencies that HUD has vetted. See the homeownership counseling list.
The Handbook says sellers, real estate agents, builders, lenders and other interested parties must not be present during counseling or give you advance copies of the counselor’s review questions with answers, and the lender must not steer you to a particular agency or pay an agency or counselor for HECM counseling (II.B.1.e).
A non-borrowing spouse
If a spouse is not a borrower, 24 CFR 206.41(b)(2) says the counselor must explain to both of you that an Eligible Non-Borrowing Spouse must obtain ownership or another legal right to remain in the home for life after the last borrower dies, or the loan becomes due and payable without the benefit of the Deferral Period; that the home must be their principal residence before and after the borrowing spouse’s death; and that they must meet all obligations of the mortgage, including property charges and upkeep. For an Ineligible Non-Borrowing Spouse, the counselor must explain that the Deferral Period does not apply and the HECM becomes due and payable when the last borrower dies (206.41(b)(3)).
To be eligible, the spouse must have been married to the borrower at closing and for the rest of the borrower’s life, been disclosed to the lender and named as an Eligible Non-Borrowing Spouse in the loan documents, and lived in the home as their principal residence (24 CFR 206.55(c)(1), eCFR). HUD’s HECM page says the amount available depends in part on the age of the youngest borrower or eligible non-borrowing spouse (HUD).
The certificate
The counselor gives a certificate that the borrower, non-borrowing spouse and non-borrowing owner, as applicable, have received counseling, and you must give the lender a copy (24 CFR 206.41(c)). The form is HUD-92902, Certificate of HECM Counseling (HUD). The Handbook says the certificate must be signed and dated by the counselor and each person required to receive counseling, that it remains valid for 180 days from the date counseling was completed, and that the lender may not charge you any fees or process the application until it receives the signed certificate (II.B.1.d). Before then, the lender may only take the application and give required disclosures, lock the expected rate, explain the program and its fees, give sample loan documents, and order a preliminary title search, a valuation model and a credit report; if the HECM closes, the lender may collect only the credit report and title search costs at closing, and if it does not close, you may not be charged for these (II.B.1.b).
Example: the 180 days
This example is only for the math, with example dates. The Handbook counts day one as the day after the date on the document.
| Item | Date |
|---|---|
| Counseling completed and certificate signed (example) | January 15, 2027 |
| Last day of the 180-day validity period | July 14, 2027 |
If the loan has not closed by then, ask the lender whether you need to repeat counseling. The amount you can borrow is figured on the lesser of the appraised value, the HECM limit or the sales price (HUD); the 2026 limit is $1,249,125 for case numbers assigned from January 1 to December 31, 2026 (Mortgagee Letter 2025-22, HUD, December 11, 2025). Only for the math: a $1,400,000 appraised value is counted as $1,249,125, and a $450,000 value as $450,000. We found no mortgagee letter after the Handbook’s counseling sections dated 04/29/2024 that changes these counseling rules; ask the lender whether any newer guidance applies.
What counseling costs
HUD Handbook 7610.1 says a housing counseling agency in HUD’s program may charge for HECM counseling if the fee is reasonable and customary, matches the services provided and does not create a financial hardship, and that the fee may not exceed the actual cost of counseling (Chapter 4-3 and the HECM fee guidance, HUD, 03/2026, read October 30, 2026). It also says:
- the agency must tell you its fees before the session and must not turn you away or withhold the certificate because you cannot pay;
- if related parties are counseled in the same session as you, the agency may charge only one fee;
- an agency should not collect a fee at the session from a client with income below 200 percent of the federal poverty level, but may charge it at closing if you were told the amount;
- you may pay the agency directly, or from the HECM proceeds at closing, shown on the Closing Disclosure; and
- a lender funding or servicing the HECM may not pay for the counseling.
The Handbook 4000.1 lists the HECM counseling fee among the costs that may be paid from loan proceeds. Ask the agency for its fee schedule before you book.
Reverse mortgage disclosures
Regulation Z requires a reverse mortgage creditor to give, in addition to other disclosures, a notice that you are not obligated to complete the loan just because you received the disclosures or signed an application, a table of total annual loan cost rates projecting the total cost of credit, an itemization of loan terms and charges, and an explanation of the table (12 CFR 1026.33(b), eCFR, text up to date as of October 28, 2026). These must be given at least three business days before consummation of a closed-end loan or the first transaction under an open-end plan (12 CFR 1026.31(c)(2), eCFR).
After closing: property charges
A HECM can become due if property charges are not paid; see the CFPB on reverse mortgage responsibilities and property tax bill payment options.
Questions to ask the counselor
- What options other than a HECM fit my situation?
- How would a HECM affect public benefits I receive and what my heirs get?
- Who in my household has to attend, and can we do it in one session?
- If my spouse is not a borrower, what must they do to stay in the home?
- What is your fee, and can it be paid from the loan at closing?
Checklist
- Pick a counselor from the lender’s list or the HUD roster and book the session yourself.
- Bring everyone who must attend: borrowers, a non-borrowing spouse, non-borrowing owners and any agent under a power of attorney.
- Keep the signed certificate and note the date 180 days later.
- Do not pay the lender any fee before it has your certificate.
- Read the total annual loan cost rate table at least three business days before closing.
You can submit a complaint at consumerfinance.gov/complaint.
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Sources
- LII: 12 U.S.C. 1715z-20, Insurance of home equity conversion mortgages for elderly homeowners
- 24 CFR 206.41: HECM counseling
- eCFR: 24 CFR 206.55, Deferral of due and payable status for Eligible Non-Borrowing Spouses, current text up to date as of October 28, 2026
- 24 CFR 206.33: HECM age of borrower
- HUD Handbook 4000.1, FHA Single Family Housing Policy Handbook (Update 18, issued August 12, 2026), PDF
- HUD: Form HUD-92902, Certificate of HECM Counseling (OMB No. 2502-0586, expires 01/31/2027, PDF)
- HUD: Handbook 7610.1, Housing Counseling Program (03/2026, PDF)
- HUD: HUD FHA Reverse Mortgage for Seniors (HECM) (no date shown on the page)
- HUD: Mortgagee Letter 2025-22, 2026 Home Equity Conversion Mortgage (HECM) Limits (December 11, 2025, PDF)
- eCFR: 12 CFR 1026.33, Requirements for reverse mortgages (Regulation Z), current text up to date as of October 28, 2026
- eCFR: 12 CFR 1026.31, General rules for subpart E (Regulation Z), current text up to date as of October 28, 2026
- CFPB: What is a reverse mortgage? (reviewed August 28, 2026)
- CFPB: What are my responsibilities as a reverse mortgage loan borrower? (last reviewed August 9, 2024)
- CFPB: Find a housing counselor
- CFPB: Submit a complaint
Disclosure: Modern Lending Solutions is not a lender, loan broker or agent for any lender or loan broker, and does not make credit decisions. Any compensation we receive is paid by participating lenders, only for advertising services. This guide is general information, not financial or legal advice.