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ARTICLE · 28 JANUARY 2025

CFPB Takes A Stance On Home Equity Contracts

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On January 15, 2025, the Consumer Financial Protection Bureau ("CPFB" or the "Bureau") took three coordinated actions related to home equity contracts (also referred to as "home equity investments,"...

United StatesFinance and Banking
Christa Bieker
Christa Bieker
Holly Spencer Bunting
Holly Spencer Bunting
Krista Cooley
Krista Cooley
Steven Kaplan
Steven Kaplan
Kerri Elizabeth Webb
Kerri Elizabeth Webb
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On January 15, 2025, the Consumer Financial Protection Bureau ("CPFB" or the "Bureau") took three coordinated actions related to home equity contracts (also referred to as "home equity investments," "home equity agreements," and "shared equity agreements"): (1) it filed an amicus brief in Roberts v. Unlock Partnership Solutions AOI, Inc., No. 1:24-cv-1374 (D.N.J.); (2) it issued a consumer advisory on home equity contracts; and (3) it published an issue spotlight providing a market overview. The CFPB briefly summarized these actions in a blog post. Although none of the CFPB's actions are binding—and may not reflect the Bureau's views after the upcoming change in administration—they are informative. Most notably, in the amicus brief, the CFPB took the position that the specific product at issue in the litigation is a residential mortgage loan. The issue spotlight and consumer advisory focus primarily on consumer education, and do not opine on whether home equity

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