[shelia]

Does anyone out there offer reverse mortgages? We are looking into offering this product but I would like to talk with someone regarding the pros and cons and/or any compliance issues we could run into if we begin this offering.

[kowsley]

Shelia, I actually am not aware of anyone that offers reverse mortgages nor have I had much experience with them in my own personal banking career; however, I have a few concerns that I would consider if looking to implement this product. As you know reverse mortgages are exempt from many of the regulatory requirements we are accustomed too; however, I do believe examiners would take a long hard look at the product, if implemented, during exams for things like UDAAP. These products generally tend to be offered to the older clientele to assist with living expenses. It would be a product that could easily be considered deceptive if not thoroughly explained when presented to the customer or if there were complaints received after closings. Just something to consider in your research and implementation.

I hope there are others on the forum that have had some experience with the product and respond to your question, I would be anxious to hear of their experiences with the product.

[MCCompliance]

We used to offer them, but do not anymore. We stopped offering them before I was in compliance, so I do not know the details to share. I know this was one product heavily scrutinized by examiners, which was probably the reason we stopped offering it.

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