This presentation is approved for one hour of CE credit for all CFPs. Send your CFP # to : Tabitha.Morris@S1L.com
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1 This presentation is approved for one hour of CE credit for all CFPs. CFPs are required to log in to the webinar using the unique link received at the time of registration. CFPs must remain on the webinar for a minimum of 50 minutes to be eligible for credit. Send your CFP # to : Tabitha.Morris@S1L.com 1
2 Welcome to the RIIA Virtual Learning Center Sponsored by: Bank of America Merrill Lynch September 3, 2014 RIIA 101 Federal Street, Suite 190, Boston, MA Ph: Fax:
3 Bank of America Merrill Lynch Exclusive Sponsor of RIIA s 2014/2015 Virtual Learning Center
4 RIIA Virtual Learning Center Webinars earn RMA CE credit Adviser Track First Wednesday of every month, 12:00 p.m. (eastern) October 1 st David Freitag, CLU, ChFC, CRPC, MML Investor Services Understand Social Security WEP and GPO for Advisers Home Office Track Third Wednesday of every month, 12:00 p.m. (eastern) September 17 th Howard Schneider, Practical Perspectives, and Dennis Gallant, GDC Research Social Security Support to Financial Advisors Insights and Opportunities 2014 Interested in presenting? Contact Kim McSheridan kim@riia-usa.org
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8 Questions Have a question? Type it into the box in the lower right hand side of your screen at any time. Q&A at the end of the presentation.
9 About Today s Presenter Shelley Giordano Chair, Funding Longevity Task Force Academic Research: Housing Wealth in Retirement Distribution
10 Jeanne Louise Calment, ( February 1875 August 1997) had the longest confirmed human lifespan on record, living to the age 122 years,164 days. 10
11 How to protect both the homeowner and the lender? HUD reconfigures FHA Mortgage Insurance Premium and applies it to the new Home Equity Conversion Mortgage (HECM)* ****** Homeownership remains with borrower/no title transfer just like any other mortgage 2. The MIP protects both the homeowner and the lender a. The loan s maturity date is at the youngest borrower s 150 th birthday b. No deficiency judgment may be taken against the homeowner or his estate c. At maturity, defined as the last homeowner dying, moving or selling, the lender is reimbursed from the FHA fund if the loan balance exceeds the home value 11
12 Incorporating Housing Wealth in Retirement Distribution Income Streams American C.E. Institute RIIA Incorporating Housing Wealth in the distribution phase Shelley Giordano James Warns One Hour Credit CFP These materials are designed to provide the reader with a general overview and understanding of the topic(s) presented and are not intended as a substitute for consultation with qualified legal counsel regarding the manner in which the laws, regulations, and guidelines covered may apply to a particular fact pattern or business model. No part of this presentation may be reproduced, forwarded, copied, or redistributed in any form or by any means without the prior written consent of Reverse Mortgage Solutions, Inc. ( RMS ). This presentation could include technical inaccuracies or typographical errors. RMS does not guarantee the accuracy of the information provided and disclaims any and all express or implied warranties, including, but not limited to, any warranties of merchantability or fitness for a particular purpose or use. This presentation should not be construed as legal advice or relied on as a sole resource for any part of the Home Equity Conversion Mortgage program. Unauthorized reproduction, forwarding, distribution or display of this copyrighted work is subject to criminal and civil penalties under federal law. 12
13 First, the Rules of the Road These strategies are not designed for the purchase of investments but rather to maximize and protect existing investments. The revised FHA HECM program has been restructured with the aim that the homeowner will use his home equity prudently to last throughout the retirement lifespan. This is exactly how you would treat all other assets. FINRA has withdrawn its recommendation that a HECM be used only as a last resort. 13
14 Where is Wealth Concentrated? 14
15 An Old Tool is New Again Home Equity Conversion Mortgage HECM Wealth Advisors Have Embraced the Managed Payment Revolving LOC 15
16 Change from Defined-Benefit to Defined-Contribution Plans to Fund Retirement 16
17 What They Fear the Most 17
18 Baby Boomers: Unprecedented Longevity 18
19 For the Average Couple in Your Practice For a 65-year-old married couple 19
20 Why take a new look at HECM Program? Consumer Safeguards Published Studies Examining HECM as a Portfolio Survival Tool Longevity Crisis in a Defined Contribution World Reduced Upfront Fees Purchase Money HECM Copyright ( ) NOT FOR CONSUMER USE 20
21 Consumer safeguards are up The FHA insured Home Equity Conversion Mortgage (HECM) which was developed by Congress in 1988 to provide a mechanism for retirees to use their housing wealth in conservative and prudent manner. The inherent consumer safeguards are summarized by the 4 Nevers * 1. Never Give Up Title to the Home 2. Never Owe More than Home is Worth 3. Never Have to Move 4. Never Make a Monthly Payment on Principal or Interest * Caveat is never say never 21
22 Dramatically Reduced Set up Fees Closing Cost Fee Chart Pre-2013 Now Servicing Fee Loan Origination Fee Closing Costs Upfront Mortgage Insurance Premium * *reduced from 2.5% to 0.5% for borrowers not taking full disbursement to pay existing obligations 22
23 HECM Primer Mortgage secured by real estate only 62 minimum age Primary home/ HUD sees the first $625,500 of home value for lending purposes Positive equity RULE OF THUMB : 50% and we are in business No monthly payments required but voluntary payments accepted No defined term Client must maintain insurance, taxes, home repairs Federally insured Voluntary payments result in increasing credit line I-O Payments P and I Payments Skip Payments Balloon Payments No Payments 23
24 Tax Free Money accessed via the HECM is considered proceeds from a loan. 24
25 Continuous Evolution Over a Quarter of a Century 1. Discourage equity-stripping through MIP pricing a. Prohibitions against accessing full credit in first year b. In circumstances where full draws are allowed, the homeowner is assessed a 2.5% upfront Mortgage Insurance Premium on home value 2. Change emphasis on MIP structure to a use fee rather than an upfront cost a. Initially, upfront MIP was 2% of home value regardless of use rate b. Today, for clients using roughly 60% or less of available credit, the Upfront MIP is.5% 3. Expected Soon : More underwriting rigor to prevent using the HECM to kick the can down the road Is a HECM suitable for this client? 25
26 Flexible Access to Cash Four Access Methods Line of Credit Monthly Payments Lump Sum Current Home Purchasing a New Home Combination 26
27 The Mass Affluent Traditional Needs-Based Client MASS AFFLUENT House Rich, Cash Poor Estate Maximization Renters w/ Few Assets Strategic Use of Home Equity 27
28 The Individual Retirement Plan and Cash Flow Survival: Can a HECM Help to Defend the Client Against These Risks? Spending Beyond Safemax Sequence of Returns Risk Reverse Dollar Cost Averaging 28
29 Sequence of Returns Risk Negative Returns in Early Years Positive Returns in Early Years 29
30 Reverse Dollar Cost Averaging 30
31 Could a HECM Strategy Mitigate Portfolio Volatility? Product Changes Spur Academic Research 31
32 Barry Sacks, J.D., Ph.D. Stephen Sacks, Ph.D. 32
33 Cash Flow Survival, Spending Beyond Safemax 33
34 34
35 Conclusions particularly in the range of initial withdrawal rates between 5 percent and 6.5 percent, we have found substantially greater cash flow survival probabilities when the reverse mortgage credit line is used in either of two active strategies rather than in the conventional, passive, strategy as a last resort. We have also found that use of these active strategies is likely to result in a higher residual net worth after 30 years than the use of the conventional strategy. 35
36 Great Minds Think Alike: John Salter, Ph.D., CFP and Harold Evensky, CFP, AIF Texas Tech University 36
37 HECM versus HELOC HELOC HECM Line of Credit Line Can Be Frozen or Cancelled Yes No Loan Subject to Recast Yes, I-O Resets No Automatic Growth in Borrowing Power No Yes Line Guaranteed to Grow Despite Home Value Payments Required Yes No No Yes Age-Based Lending No Yes ( 62+) 37
38 Glidepath Concept 38
39 Risk Management Tool : Comparing Cash Flow Reserve Bucket Strategies At the 30-year mark of retirement, or when our client is 92, we see the probability of their portfolio having a positive value is approximately 52 percent. When we implement the SRM ( Standby Reverse Mortgage) strategy we find the probability dramatically increases to 78 percent. When the line of credit is used to fund living after the portfolio is exhausted, the probability increases to 82 percent. 39
40 Conclusions The Standby Reverse Mortgage strategy is appealing for four primary reasons: 1. It diminishes the size of the cash bucket and thus the opportunity cost of holding cash; 2. It provides flexibility in that the investment bucket is not sold during bear markets; 3. It allows the retiree to decide how much home equity is used to meet needs; 4. and most importantly, it increases the life expectancy of an investor s nest egg. 40
41 Simply Put : Don t Feed the Bear Draw from IP only when portfolio returns are positive. Use HECM instead. 41
42 Replacing a Mortgage with a HECM? Michael kitces.com There's a danger than equities won't perform as expected, and fail to generate a return in excess of the borrowing cost over a relevant time period. And even if the returns do ultimately add up, the ongoing payment obligations for a traditional mortgage create a "sequence of returns" risk for the retiree, where withdrawals to handle the mortgage payments could so deplete the portfolio during an extended period of bad returns that there may not be enough money left over for when the good returns finally arrive. From this perspective, retirees should perhaps consider the reverse mortgage instead. While such loans have been relatively unpopular - due in part to their high costs, and because they're often viewed as a borrowing option of last resort - the reality is that the lack of any cash flow obligations for a reverse mortgage actually allows it to eliminate the sequence risk from the mortgage-in-retirement strategy. In fact, over a long period of time, using a reverse mortgage in retirement can result in materially greater wealth when equities do perform as desired, as the reverse mortgage maintains a greater amount of household leverage, even while reducing the exposure to the impact of an unfavorable sequence of returns. 42
43 Compared to a Traditional Mortgage Make a down payment and then monthly mortgage payments until paid off Mortgage There is a cost for all of the mortgage payments Probably 2 to 3 times the loan amount toolsforretirementplanning.com 43
44 How would portfolio perform without P and I payments? 44
45 Voluntary Payments on HECM? Housing Wealth Optimizer Calculator Every payment against the HECM adjustable rate HECM results in a corresponding increase in the available Line of Credit. If needed down the road, the Line of Credit can be converted to monthly tenure payments: 45
46 HELOC v. HECM Rates Tom Davison, Ph.D., CFP toolsforretirementplanning.com The green line is the RMLOC is represented as the 1-month LIBOR, adding in the current 1.25% MIP and a margin of 2.25%. The black is HELOC, estimated by adding 0.5% to the history of prime. 46
47 Scheduled Monthly Payments Provide Resilience 47
48 New Study Confirms Protective Power of Housing Wealth: The 6% Rule Gerald Wagner, Ph.D. Scheduled Payment from HECM? Portfolio Alone Portfolio Alone Retirement Horizon Initial Withdrawal Rate Probability of Success Outcome 30 years 4% 90% Spending Limited 30 years 6.0% 36% Not Viable Tenure Plan 30 years 6.0% 90% + Greater Spending Portfolio Alone 37 years 3.25% 90% Spending Limited Tenure Plan 37 years 5.5% 90.6% Longevity Protection Assumptions: 63-yr-old Client; $800,000 IP, minimum 60% Equities; $450,000 Home 48
49 Wagner: 60+% Increased Portfolio-based Spending With Reverse Mortgage Monthly Income Portfolio alone: 3.75% Sustainable Withdrawal Portfolio + Monthly Income: 6% Sustainable Withdrawal Wagner, Journal of Financial Planning 49
50 Monthly Draw : Add $1200 a month from Housing Wealth Retires at Age 66 First Year Income Need $ 72, K $ 750,000 Cash $ 325,000 Initial Social Security $ 25,571 Housing Wealth $ 500,000 Add Home Equity Draws $ 14, 400 a year 50
51 Outcome without Home Equity Draws 51
52 Outcome with $1,200 Monthly HECM Draws 52
53 Comparison Without a HECM With HECM Draws of $1,200/mo. 53
54 HECM Scheduled Monthly Payments HECM RETIREMENT CALCULATOR 54
55 Retained Housing years Estimated Values 55
56 Jack Guttentag, Professor Emeritus University of Pennsylvania Using a HECM Reverse Mortgage to Insure Against Running Out of Money December 17, 2012 Is there a way for seniors living off of retirement assets to insure themselves against running out of money? Today, an alternative that keeps your assets in your own hands is available to any senior with significant equity in the home they occupy as their principal residence. The alternative is the HECM reverse mortgage administered by FHA. 56
57 HECM LOC as Liquidity Insurance Estimated Values 57
58 Effective Interest Rate Available Credit by Interest Rate Youngest Borrower s Age % 52.6% 55.1% 57.5% 59.7% 62.1% 64.6% 66.0% 6% 42.0% 45.0% 48.3% 51.1% 54.5% 58.1% 60.2% 7% 34.3% 37.9% 41.7% 45.1% 48.9% 53.2% 55.8% 8% 28.1% 31.9% 36.1% 40.0% 44.2% 49.0% 52.1% 9% 22.9% 26.9% 31.3% 35.2% 40.0% 45.3% 48.4% 10% 18.5% 22.5% 26.9% 31.2% 36.1% 41.8% 45.1% Tom Davison, toolsforretirementplanning.com 58
59 Rising Interest Rates Will Reduce INITIAL Loan Proceeds HECM LINE OF CREDIT BORROWER AGE 66 HOME VALUE $500,000 EXPECTED RATE OF PROVIDES INITIAL PROCEEDS OF 3% $274,500 4% $274,500 5% $274,500 6% $210,500 7% $169,000 8% $132,000 59
60 Journal of Financial Planning, December, 2013 Salter,Pfeiffer,Evensky Together, these findings suggest that the adage of using a reverse mortgage as a last resort could be a huge mistake in a rising interest rate environment where a retiree waits to set up a line of credit in the future. In addition, the current retirement landscape, due to low interest rates, should incentivize the consideration of reverse mortgages in retirement for many financial planners and their clients. 60
61 Another Radical Change: Purchase Money HECM Also known as HECM for Purchase Finance the purchase of a new primary residence by getting a HECM on the new home as part of the purchase transaction, instead of getting a traditional mortgage or paying all cash. No Debt Service Requirement. Easier to Qualify. 61
62 Use Your Equity to Fund a Purchase Appraised Value-Lump Sum = Down Payment $600,000 - $300,000 = $300,000 62
63 Upsizing with Purchase Money HECM. 66 Year Old Without HECM Financing Sales Price for Departure Home $ 500,000 Less Selling Costs ( Commission, Fees) $ 40,000 Net Proceeds from Departure Home $ 460,000 New Home Price, Paid in Cash $ 700,000 Withdrawal from Assets to Accomplish Cash Sale $ (240,000) With HECM Financing Sales Price for Departure Home $ 500,000 Less Selling Costs (Commission, Fees) $ 40,000 Net Proceeds from Departure Home $ 460,000 New Home Price $ 700,000 Financing Available from HECM $ 300,000 Cash Required from Net Proceeds $ 400,000 Liberated Funds Remaining for Retirement Needs ($240K Assets protected + $60K residual from departure home) $ 300,000 63
64 Upsizing with Purchase Money HECM How Cash Retention Affects Retirement Outcome Balanced II Only Average Risk Tolerance Low Probability Retain $300,000 Higher Probability 64
65 HECM Purchase Money Calculator 65
66 Defer Social Security Without Losing Income Delay Social Security :Funding the Income Gap with a Reverse Mortgage Thomas C. B. Davison, MA, Ph.D, CFP NAPFA Registered Financial Advisor toolsforretirementplanning.com Using HECM Line of Credit to fund the gap in income created by delaying Social Security can dramatically improve a retirement income plan.. 66
67 Funding the Income Gap 67
68 Social Security at 62 68
69 Delay Social Security, HECM to Fund Income Gap 69
70 5% v. 90% Success Rate TIME IN THE MARKET 70
71 A Common Theme The bottom line to all of these strategies, though, is fairly straightforward: reverse mortgages may work far better when they're done not as a last resort, but as a part of an ongoing retirement plan. --Michael Kitces, Partner & Director of Research Pinnacle Advisory Group 71
72 Conclusion : Research Proves Positive Role of Housing Wealth Consumer Safeguards Protect Housing Asset Draws from Housing Wealth Protect Investment Portfolio HECM LOC Provides Benefits that HELOCs Do Not HECM LOC Insures Access to Housing Wealth for Future Terminal Wealth Enhanced Greater Withdrawal Rates Possible Substitutes Income During Social Security Deferral Years Inclusion of Housing Wealth in Retirement Matrix Allows more time in the market 72
73 An Adviser Website 73
74 Bibliography Prepared by ToolsforRetirementPlanning.com Research from Gerald Wagner and Barry and Stephen Sacks A variety of strategies can be used to fund spending when combining reverse mortgage and portfolio draws. Wagner s paper examines 5 strategies, such as a using the reverse mortgage line of credit first before any portfolio withdrawals, fixed monthly draws for 30 years, or monthly tenure advance guaranteed to continue as long as the homeowner stays in the house. All the strategies improved retirement withdrawals. Benefits of each strategy are examined. Wagner, Gerald C The 6.0 Percent Rule. Journal of Financial Planning, 26(12): With only the portfolio to fund spending, sustainable withdrawals were 3.75%. In contrast, With a 30-year spending horizon and first-year withdrawal of 6.0 percent, reverse mortgage scheduled advances as a portfolio supplement give spending success levels of 88 to 92 percent. Even with a first-year withdrawal of 6.5 percent, success levels are still 83 to 86 percent. This paper provides financial planners with a review of the relative merits of using a reverse mortgage as a retirement spending supplement. After 15 years, the client s estate value is 10 to 30% higher using the reverse mortgage plus portfolio than relying on the portfolio alone, combining current portfolio, home value and deducting the reverse mortgage loan balance. Sacks, Barry H., and Stephen R. Sacks Reversing the Conventional Wisdom: Using Home Equity to Supplement Retirement Income. Journal of Financial Planning 25(2): This paper examines three strategies for using home equity, in the form of a reverse mortgage credit line, to increase the safe maximum initial rate of retirement income withdrawals. Standby Reverse Mortgage: Borrow from then repay Line of Credit to augment Portfolio withdrawals A Standby Reverse Mortgage is a strategy of borrowing from the HECM Line of Credit when the portfolio has suffered a significant downturn and repaying it after the portfolio recovers so it is available to help future spending in the future. The team of Salter, Pfeiffer and Evensky introduced this concept. Pfeiffer, Shaun, C. Angus Schaal, and John Salter HECM Reverse Mortgages: Now or Last Resort? Journal of Financial Planning 27(5) This study outlines recent changes in the reverse mortgage market and investigates plan survival rates for distribution strategies that establish a Home Equity Conversion Mortgage (HECM) reverse mortgage line of credit at the beginning of retirement and as a last resort. Early establishment of an HECM line of credit in the current low interest rate environment is shown to consistently provide higher 30-year survival rates than those shown for the last resort strategies. The early establishment survival advantage for real withdrawal rates at or above 5 percent is estimated to begin between 15 and 20 years after loan origination and is shown to be as high as 31 percentage points, or 85 percent, greater than the last resort survival rates. Pfeiffer, Shaun, John Salter, and Harold Evensky Increasing the Sustainable Withdrawal Rate Using the Standby Reverse Mortgage. Journal of Financial Planning 26(12): Sustainable withdrawal rates jumped from 3.15% to 5 and 6% with a standby HECM Line of Credit. The real key, not directly addressed in the article, is the size of the line of credit in realation to the portfolio. Clients had an important boost in sustainable spending with a line of credit as small as 8% 10% of the portfolio. The authors note The findings from this research suggest that the adage of using a reverse mortgage as a last resort could be a huge mistake in a rising interest rate environment where a retiree waits to set up a line of credit in the future. 74
75 ToolsforRetirementPlanning.com Michael Kitces notes: this latest version looks specifically at the maximum safe withdrawal rate that can be sustained by the strategy, and is updated for the latest reverse mortgage rules that took effect this fall. Using reduced market expectations (relative to historical standards), the results show a significant improvement in safe withdrawal rates (in the neighborhood of 5% even with lower return assumptions) under the standby reverse mortgage scenario, driven in part by the favorable liquidation effects and in part simply because the strategy taps home equity and introduces additional assets to the retirement balance sheet. clients who wish to implement the strategy should look at establishing the line of credit sooner rather than later (while interest rates are still low), even if there is no intention to borrow until an extended period into the future (to reduce the risk that rates will be higher and borrowing limits will be lower if the client waits until funds actually need to be used). Salter, John, Shaun Pfeiffer, and Harold Evensky Standby Reverse Mortgages: A Risk Management Tool for Retirement Distributions. Journal of Financial Planning 25 (8): The authors propose using an HECM Saver reverse mortgage as a risk management tool in conjunction with a two-bucket investment strategy to increase the probability a client will be able to meet predetermined retirement goals. Salter, John, Shaun Pfeiffer, and Harold Evensky Standby Reverse Mortgages: A Risk Management Tool for Retirement Distributions. Presentation sponsored by Genworth. Document created August 17, Talk based on Journal of Financial Planning 2012 article. Additional charts of interest, including details of HECM balance usage. For example: Less than 25% of plans had a HECM loan balance in any year, and about 5% of months had a plan with 100% of line of credit used Evensky, Harold. June Questions. Harold Evensky on ETFs, Reverse Mortgages, and the Most Important Investment in the Coming Decade. Journal of Financial Planning 26(6): Short discussion described in detail in other papers. our conclusion was, anyone who qualified for it should consider doing it. And there s a high probability, based on our simulations, that most investors would never have occasion to draw on it, but as I said, we see it as an insurance policy. Reverse Mortgages in Financial Planning General Kitces, Michael Taking a Fresh Look at Reverse Mortgages in Retirement. AICPA Advanced Personal Financial Planning Conference. January 21. An updated version of earlier talks. Kitces, Michael HECM Reverse Mortgages Current Borrowing Limits May Not Last Much Longer. Nerd s Eye View. December 4. Kitces, Michael Is a Reverse Mortgage Better Than Keeping a Traditional Amortizing Mortgage in Retirement? Nerd s Eye View. September 18. the fact remains that all else being equal, traditional amortizing mortgages introduce additional sequence risks to the household leverage scenario (above and beyond just the risk that the portfolio fails to outperform the loan) that reverse mortgages alleviate, which should make reverse mortgages especially appealing for retirees who believe it s worth the risk of maintaining a mortgage and a portfolio side by side in retirement. Kitces, Michael Will New Reverse Mortgage Changes Make Them a Better Financial Planning Tool? Nerd s Eye View. September Kitces, Michael HUD Eliminating Fixed-Rate HECM Standard Reverse Mortgages, But HECM Saver Option Remains. Nerd s Eye View. February Kitces, Michael Evaluating Reverse Mortgage Strategies. The Kitces Report. November. Broad review of how reverse mortgages can fit in client s retirement plans. Kitces, Michael A Fresh Look at the Reverse Mortgage. The Kitces Report. October. Summarizes the internal workings of reverse mortgages. Lynch, Nicholas C. and Charles R Pryor Know the costs, benefits and alternatives for this retirement funding tool. Journal of Accountancy. July. Includes section on family-funded alternatives to reverse mortgages 75
76 ToolsforRetirementPlanning.com Munnell, Alicia H. and Steven A. Sass The Government s Redesigned Reverse Mortgage Program. Center for Retirement Research at Boston College. January, Number Reverse mortgages, which allow retirees to tap their home equity, are insured by the government. The financial crisis hurt both the government s insurance fund and the borrowers: Declining home prices led to losses when homes were sold; More borrowers defaulted. In response, the government has redesigned the program by: creating a single loan option with a lower limit and fees; limiting initial withdrawals; and requiring financial assessments of borrowers. These changes should help reduce pressure on the insurance fund and make defaults less likely Conclusion: All these changes should be viewed as positive. A better customer experience combined with lower fees will also make reverse mortgages a more attractive option for retirees. Quinn, Jane Bryant A great reverse mortgage idea: Take a credit line now. August 15. But there s a valuable new opportunity at hand, for borrowers who don t need extra money now. You borrow as early as age 62 and take the mortgage in the form of a credit line instead of all-cash. You can borrow against the credit line at any time, but you don t have to take the money now. More important, this credit line grows every year greatly increasing your borrowing power in the future. Jack Guttentag posts as The Mortgage Professor Guttentag discusses reverse mortgages and other types of mortgages on his website. Wide variety of posts available. Technical Details for Reverse Mortgage Nerds HUD handbook for Home Equity Conversion Mortgages (4235.1) HUD Mortgagee Letters Official HUD communication on Reverse Mortgages HUD s site for lenders: Home Equity Conversion Mortgages for Lenders (HECMs) The purpose of this page is to help FHA approved lenders by providing links to policy, guidance and tools that help in the origination and servicing of HECM loans. 76
77 Questions? 77
78 This presentation is approved for one hour of CE credit for all CFPs. CFPs are required to log in to the webinar using the unique link received at the time of registration. CFPs must remain on the webinar for a minimum of 50 minutes to be eligible for credit. Send your CFP # to : Tabitha.Morris@S1L.com 78
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